GR 165355; (September, 2012) (Digest)
March 17, 2026GR 123935; (December, 2001) (Digest)
March 17, 2026G.R. No. B.M. No. 44, SBC No. 609, SBC No. 616 February 24, 1992
EUFROSINA Y. TAN, MOISES B. BOQUIA, and HERVE DAGPIN, complainants, vs. NICOLAS EL. SABANDAL, respondent.
FACTS
The respondent, Nicolas Sabandal, was previously denied admission to the Philippine Bar in 1983 for unauthorized practice of law. After several motions, the Court, in a 1989 Resolution, reconsidered and allowed him to take the lawyer’s oath based on his plea for mercy and testimonials to his good moral character. Before the oath could be administered, the original complainants filed motions for reconsideration. The Court then required an inquiry into Sabandal’s current moral fitness.
The investigation revealed a pending civil case for reversion (Republic vs. Sabandal) wherein the government alleged he secured a free patent and title for swampland, which was not susceptible to such acquisition, and later mortgaged it. The Court noted Sabandal’s failure to disclose this pending case during his petitions for reconsideration, despite his duty of candor.
ISSUE
Whether respondent Nicolas Sabandal possesses the requisite good moral character to be admitted to the practice of law.
RULING
No. The Supreme Court denied Sabandal’s admission, recalling its 1989 Resolution. The practice of law is a privilege reserved for individuals proven to be of good moral character. While there were testimonials as to his character, they were rendered without knowledge of the specific facts of the reversion case.
The Court emphasized that good moral character includes common honesty and, most importantly, truthfulness and candor. Sabandal’s act of concealing the pendency of a serious civil case alleging dishonesty in a land transaction from the Court demonstrated a lack of these essential qualities. His failure to reveal this information, which directly reflected on his honesty and fair dealing, was a fatal omission. The testimonials submitted could not outweigh this concrete evidence of dishonesty and lack of candor. Consequently, he was found unfit for the legal profession.