G.R. No. B.M. No. 2540; September 24, 2013
IN RE: PETITION TO SIGN IN THE ROLL OF ATTORNEYS, MICHAEL A. MEDADO, Petitioner.

FACTS

Petitioner Michael A. Medado passed the 1979 Bar Examinations and took the Attorney’s Oath on May 7, 1980. He was scheduled to sign the Roll of Attorneys on May 13, 1980, but failed to do so, allegedly because he misplaced the notice while on vacation. Years later, he discovered the notice among old files and realized his omission, having mistakenly believed that signing an attendance record at the oath-taking venue sufficed. He continued working in corporate and taxation law, operating under the belief that signing the roll was not urgent for his status. The issue resurfaced in 2005 when he needed a roll number for MCLE compliance. He filed the instant petition on February 6, 2012, seeking permission to sign the roll.
The Office of the Bar Confidant (OBC) recommended denying the petition due to gross negligence and misconduct, citing a lack of valid justification for the prolonged failure to complete the admission requirement.

ISSUE

Whether petitioner Michael A. Medado should be allowed to sign the Roll of Attorneys despite his failure to do so for over thirty years.

RULING

The Supreme Court granted the petition but imposed penalties. The Court reasoned that outright denial would equate to disbarment, a penalty reserved for serious ethical breaches not present here. Medado demonstrated good faith by voluntarily filing the petition to rectify his omission, candidly admitting his apprehension. His unblemished professional record, holding significant legal positions without any disqualification action, prima facie shows good moral character and fitness for the Bar.
However, the Court did not fully exculpate Medado. While his initial belief about signing an attendance record may have been an honest mistake of fact, his subsequent realization and continued practice of law without completing admission requirements constituted a willful mistake of law and unauthorized practice. Everyone is presumed to know the law; ignorance does not excuse. His prolonged inaction warranted sanction.
Consequently, the Court allowed Medado to sign the Roll of Attorneys one year after receipt of the resolution, effectively suspending him from practice during that period. He was also fined ₱32,000 for unauthorized practice. The Court sternly warned that engaging in practice before signing the roll would be severely dealt with. The ruling balances compassion for an otherwise qualified candidate with the need to uphold the integrity of the legal profession and its admission protocols.