A.M. No. 545-SBC. December 26, 1974.
Purisima Barba, complainant, vs. Hector S. Pedro, respondent.

FACTS

Hector S. Pedro passed the 1956 Bar Examinations but was prevented from taking the lawyer’s oath due to an administrative complaint for immorality filed by Purisima Barba. The complaint alleged that Pedro had amorous relations with Barba, resulting in the birth of a child, and failed to fulfill his promise to marry her, instead marrying another woman. In 1969, the Court initially resolved to allow Pedro to take his oath upon showing proof of action regarding his child, but this was suspended after Barba objected, claiming an affidavit of withdrawal she signed was misrepresented to her. An investigation confirmed Barba believed the document was for recognizing the child, not for withdrawing her opposition.
For eighteen years since passing the bar, Pedro’s admission was deferred. During this period, he worked as a community development worker and submitted certifications from local officials and civic groups attesting to his good conduct. Barba, however, maintained her firm opposition, contending Pedro’s failure to marry her demonstrated a lack of good moral character essential for bar membership.

ISSUE

Whether Hector S. Pedro, after eighteen years of deferred admission due to a proven act of immorality, should now be allowed to take the lawyer’s oath and be admitted to the Philippine Bar.

RULING

Yes, the Supreme Court granted Pedro’s plea for admission to the bar. The legal logic balances the requirement of good moral character with the principles of rehabilitation, atonement, and the passage of time. While the Court unequivocally condemned Pedro’s past misconduct—his deceit and failure to marry Barba after fathering a child—as a serious transgression against the high moral standards demanded of lawyers, it ruled that the prolonged deferment of his privilege for eighteen years constituted sufficient punishment and retribution.
The Court emphasized that during the long interim, Pedro had lived a blameless life, as evidenced by community testimonials, and had thereby rehabilitated himself. It analogized the situation to the prescription of crimes, suggesting that even grave offenses are not subject to indefinite sanction. Furthermore, the Court noted the human frailty involved in such personal transgressions and that blame is not solely attributable to one party. However, the grant of admission was made conditional. Pedro must continuously comply with his moral and legal obligations to support his illegitimate child. His good standing in the bar is expressly contingent upon fulfilling this paternal duty. The resolution setting aside the suspension of his oath-taking was thus reinstated.