Title (with GR IN THE MATTER OF THE INTEGRATION OF THE BAR OF THE PHILIPPINES
No. and Date) January 9, 1973
Ponente (RESOLUTION) PER CURIAM
Doctrine ● Courts have inherent power to supervise and regulate the practice of
law.
● The inherent power of the Supreme Court to regulate the Bar includes
the authority to integrate the Bar.
● Because the practice of law is privilege clothed with public interest, it
is fair and just that the exercise of that privilege be regulated to
assure compliance with the lawyer's public responsibilities.
● These public responsibilities can best be discharged through collective
action; but there can be no collective action without an organized
body; no organized body can operate effectively without incurring
expenses; therefore, it is fair and just that all attorneys be required to
contribute to the support of such organized body; and, given existing
Bar conditions, the most efficient means of doing so is by integrating
the Bar through a rule of court that requires all lawyers to pay annual
dues to the Integrated Bar.
● If the Court has inherent power to regulate the Bar, it follows that as
an incident to regulation, it may impose a membership fee for that
purpose.
Facts The petition in Adm. Case No. 526 formally prays the Court to order the integration of
the Philippine Bar, after due hearing, giving recognition as far as possible and
practicable to existing provincial and other local Bar associations.
Issue/s
(1) Does the Court have the power to integrate the Philippine Bar? (YES)
(2) Would the integration of the Bar be constitutional? (YES)
SC Ruling
Anent the first issue, the Court is of the view that it may integrate the Philippine Bar
in the exercise of its power, under Article VIII, Sec. 13 of the Constitution, "to
promulgate rules concerning pleading, practice, and procedure in all courts, and the
admission to the practice of law." Indeed, the power to integrate is an inherent
part of the Court's constitutional authority over the Bar. In providing that "the
Supreme Court may adopt rules of court to effect the integration of the Philippine Bar,"
Republic Act 6397 neither confers a new power nor restricts the Court's inherent
power, but is a mere legislative declaration that the integration of the Bar will promote
public interest or, more specifically, will "raise the standards of the legal profession,
improve the administration of justice, and enable the Bar to discharge its public
responsibility more effectively."
Resolution of the second issue — whether the unification of the Bar would be
constitutional — hinges on the effects of Bar integration on the lawyer's constitutional
rights of freedom of association and freedom of speech, and on the nature of the dues
exacted from him.
1. Freedom of Association.
To compel a lawyer to be a member of an integrated Bar is not violative of his
constitutional freedom to associate (or the corollary right not to associate).
Bar integration does not compel the lawyer to associate with anyone. He is free to
attend or not attend the meetings of his Integrated Bar Chapter or vote or refuse to
vote in its elections as he chooses. The body compulsion to which he is subjected is the
payment of annual dues.
Otherwise stated, membership in the Unified Bar imposes only the duty to pay dues in
reasonable amount. The issue therefore, is a question of compelled financial support of
group activities, not involuntary membership in any other aspect.
Assuming that Bar integration does compel a lawyer to be a member of the Integrated
Bar, such compulsion is justified as an exercise of the police power of the State. The
legal profession has long been regarded as a proper subject of legislative regulation
and control. Moreover, the inherent power of the Supreme Court to regulate
the Bar includes the authority to integrate the Bar.
2. Regulatory Fee.
For the Court to prescribe dues to be paid by the members does not mean that the
Court levies a tax.
If the Court has inherent power to regulate the Bar, it follows that as an
incident to regulation, it may impose a membership fee for that purpose. It
