G.R. No. L-33786 January 9, 1973
IN THE MATTER OF THE INTEGRATION OF THE BAR OF THE PHILIPPINES.

FACTS

The Supreme Court had before it a petition filed in Administrative Case No. 526, formally praying for an order to integrate the Philippine Bar. The Court had conducted hearings, received written oppositions and memoranda, and closely observed developments on the matter since 1962. In 1970, the Court created the Commission on Bar Integration to ascertain the advisability of unification. Subsequently, Republic Act No. 6397 was enacted in 1971, expressly authorizing the Supreme Court to adopt rules to effect Bar integration within two years. The Commission submitted its Report in 1972, containing exhaustive factual data, arguments on constitutionality, the overwhelming sentiment of the bench and bar, and a proposed Court Rule which had been subjected to a nationwide plebiscite among lawyers.

ISSUE

The core issues for resolution were: (1) Whether the Supreme Court possesses the power to integrate the Bar; (2) Whether such integration would be constitutional; and (3) Whether the Court should ordain integration at that time.

RULING

The Supreme Court resolved all issues affirmatively and ordained the integration of the Philippine Bar. On the first issue, the Court held that the power is constitutionally vested in the Supreme Court under Article VIII, Section 13 of the 1935 Constitution, which grants the Court the power to promulgate rules concerning the admission to the practice of law and the integration of the Bar. This inherent regulatory power over the legal profession was further affirmed and supported by the explicit legislative grant in Republic Act No. 6397 .
On the second issue, the Court ruled that Bar integration is perfectly constitutional. It defined integration as the official unification of the entire lawyer population, requiring membership and financial support as a condition for the practice of law, thereby recognizing the lawyer as an officer of the court. The Court emphasized that such integration is a valid exercise of the state’s police power, designed as a means to elevate professional standards, improve the administration of justice, and enable the Bar to discharge its public responsibilities more effectively. The compelled association and financial contribution were justified as incidental to the overriding public interest served by a unified, self-regulating profession.
Finally, on the third issue, the Court found the integration imperative and timely. It based this conclusion on the Commission’s comprehensive Report, which demonstrated overwhelming nationwide support from both bar associations and individual lawyers, as evidenced by the plebiscite results where 93.14% of voting lawyers favored the proposed rule. The Court was convinced that integration had become a necessary tool to foster professional cohesion, ethical conduct, and effective participation in the legal system. Consequently, the Court promulgated the attached Court Rule, effecting the integration of the Bar effective January 16, 1973.