In Re: Petition to Re-acquire the Privilege to Practice Law in the Philippines,

Epifanio B. Muneses

B.M. 2112, July 25, 2012

Facts:

Atty. Epifanio Muneses filed a petition to the Office of the Bar Confidant praying that he be
granted the privilege to practice law in the Philippines.
The Petitioner lost his privilege to practice law when he became citizen of the United States.
After two decades, he reacquired his Philippine citizenship pursuant to “Citizenship Retention
and Re-Acquisition Act of 2003 (R.A. 9225). He intends to retire in the Philippines and if
granted, resume the practice of law.

Issue:

Whether or not Atty. Epifanio Muneses can re-acquire the privilege practice law in the
Philippines

Ruling:

YES.

The Court reiterates that Filipino citizenship is a requirement for admission to the bar and a
continuing requirement for the practice of law. Under R.A. 9225, those who lost their citizenship
by means of naturalization as citizens to foreign country are deemed to have re-acquired their
Philippine Citizenship upon taking the oath of allegiance to the Republic. A Filipino lawyer who
becomes a citizen of another country and later re-acquires his Philippine citizenship under R.A.
9225 remains to be a member of the Philippine bar.