CASE 1: In The Matter of the Integration of the Bar of the Philippines, January 9, 1973

FACTS: In 1970, the Supreme Court created the Commission on Bar Integration (CBI) to ascertain the
advisability of unifying the Philippine Bar. In 1971, the Congress passed HB 3277 (An Act Providing for
the Integration of the Philippine Bar, and Appropriating Funds Therefor). President Marcos signed it and
it became RA 6397. In 1972, the CBI submitted its Report with the earnest recommendation to ordain
the integration of the Philippine Bar through the adoption and promulgation of an appropriate Court
Rule. The Report, alongside the proceedings in Administrative Case 526 and the views and sentiments
of the Board of Consultants and the Philippine Bench and Bar, prayed for such integration.
ISSUE/S: WON the integration of the Bar is constitutional.
HELD: Yes. The integration of the Bar is constitutional.
RATIO: The CBI Report defines the Bar Integration as the official unification of the entire lawyer
population of the Philippines, requiring membership and financial support of every lawyer as sine qua
non to the practice of law and the retention of his name in the Roll of Attorneys. It is based on the
recognition that a lawyer is an officer of the court. It improves the position of the Bar as an instrument
of justice and rule of law. It fosters cohesion among lawyers and ensures the promotion of the
objectives of the legal profession. The constitutionality of the Bar Integration hinges on the
constitutional rights of freedom of association and freedom of speech. As the practice of law is a
privilege vested with public interest, it can best discharge its public responsibilities through collective
action. Collective action can only be done through an organized body.
To compel a lawyer to be a member of an Integrated Bar does not violate his constitutional freedom to
associate because integration does not make a lawyer a member of any group of which he is not
already a member. Integration only provides an official national organization for the well-defined but
unorganized and incohesive group of which every lawyer is already a member. Also, an Integrated Bar
serves to elevate the educational and ethical standards of the Bar with the goal of improving

the quality of the States legitimate interest. Even assuming that a lawyer is compelled to join the
Integrated Bar, it is still a justified compulsion as it is an exercise of the police power of the State in
regulating and controlling the legal profession. Also, the inherent power of the Supreme Court to
regulate the Bar includes the authority to integrate it. NOTE: This case falls under Canon 7 but this
Canon is not explicitly provided for in the case. However, the relation can be seen. Canon 7 provides
that a lawyer shall at all times uphold the integrity and dignity of the legal profession and support
the activities of the integrated bar. In using the word shall, this Canon makes it mandatory for all
lawyers to: (1) uphold the integrity and dignity of the legal profession, and (2) support the activities of
the Integrated Bar. In being a member of the Integrated Bar, a lawyer has certain responsibilities,
which, if complied with, will uphold the integrity and dignity of the legal profession. Therefore, it is
neither unlawful to have a Bar Integration nor be a member of an Integrated Bar.