FACTS: Respondent Nicolas El. Sabandal passed the 1978 Bar Examinations but because of pending administrative complaints filed against him regarding instances when he called himself “attorney” knowing full well that he was not yet admitted to the Bar, he was not allowed to take the lawyer’s oath.  Oppositor’s evidence sufficiently show that respondent had held himself out as an attorney in the agrarian, civil and criminal cases and he was paid for his “legal services”

He then filed a petition to be admitted to the Philippine Bar and to be allowed to sign the Roll of Attorneys.  In a resolution promulgated on November 29, 1983 respondent petition was denied.  Respondent asks for forgiveness, understanding and benevolence and promises that, if given a chance to be a member of the Phil. Bar, he would always be faithful to the lawyer’s oath and conduct himself in an upright manner.


HELD: Whether or not respondent shall be admitted to the Philippine Bar rests to a great extent in the sound discretion of the Court.  An applicant must satisfy the Court that he is a person of good moral character, fit and proper to practice law.  Sabandal hereby allowed to take the lawyer’s oath.


TAN VS. SABANDAL, 170 SCRA 211, 2/10/89- Admission to the Bar