Bar Matter No.

2112 July 24, 2012

In Re: Petition Re-Acquire the Privilege to Practice Law in the Philippines, Epifanio B. Muneses,
REYES, J.:
Facts:
Epifanio B. Muneses became a member of the Integrated Bar of the Philippines (IBP) in March
21, 1966. He lost his privilege to practice law when he became a citizen of the United States on
August 28, 1981. On September 15, 2006, he re-acquired his Philippine citizenship pursuant to
R.A. 9225 or the “Citizenship Retention and Re-Acquisition Act of 2003”by taking his oath of
allegiance as a Filipino citizen before the Philippine Consulate General in Washington D.C., USA.
On June 8, 2009, a petition was filed by Muneses with the Office of the Bar Confidant (OBC)
praying the he be granted the privilege to practice law in the Philippines.
Issue:
Whether or not the petitioner should be granted the privilege to practice law in the Philippines
Ruling:
Yes. A Filipino lawyer who becomes a citizen of another country and later re-acquires his
Philippine citizenship under R.A. No. 9225 remains to be a member of the Philippine bar.
However, as stated by the Court in a similar petition by Dacanay (Bar Matter No. 1678, dated
December 17, 2007), the right to resume the practice of law is not automatic. R.A. No 9225
provides the need to apply with the proper authority for a license or permit to engage in such
practice. After all the requirements were satisfactorily complied with by Muneses, the OBC
recommended that the petitioner be allowed to resume his practice of law. Thus, the petition
of Atty. Epifanio B. Muneses is hereby GRANTED, subject to the condition that he shall re-take
the Lawyer’s Oath on a date to be set by the Court and subject to the payment of appropriate
fees.
MICHELLE YAP v. ATTY. GRACE C. BURI [AC. No.11156, Mar 19, 2018 ]

Facts:

The instant case stemmed from the complaint of Michelle Yap against respondent Atty. Grace
C. Buri for refusing to pay her monetary obligation and for filing a criminal case of Estafa against
her based on false accusations.

Michelle Yap was the vendor in a contract of sale for a condominium unit, while Atty. Buri was
the vendee. Atty. Buri made an offer to purchase the property at a reduced price of P1,200,000
from P1,500,000. Atty. Buri paid P1,000,000 and the P200,000 remains unpaid. She insisted she
would pay the balance in monthly installments without specifying the amount to be paid on
each installment. Due to their relationship, Atty. Buri being a close friend and her daughter's
godmother. Yap trusted her and she gave Atty. Buri the full and immediate possession of the
condo unit. When Yap finally asked for the remaining balance, Buri said pay it in a monthly
installment of P5,000 until fully paid. Yap disagreed and Atty. Buri said she would cancel the
sale. Thereafter, Buri also started threatening her through text messages and later filed an
estafa case, alleging that Yap failed to return the money. When the courts asked for her
answer, she failed to comply. The IBR recommended her suspension.

Issue:

Whether or Not the IBR was correct in their suspension of Atty. Buri

Ruling

Yes, there is no sufficient reason to overturn the recommendation of the IBR. Atty. Buri, instead
of paying Yap the remaining balance, she opted to threaten her and file a criminal case against
her as a strategy of intimidation. She took advantage of her knowledge of the law and clearly
resorted to threats and intimidation in order to get away with what she wanted, constituting a
gross violation of professional ethics and a betrayal of public confidence in the legal profession.