**Facts:**
1. **Bar Admission and Initial Conduct:** Atty. Carlos C. Rusiana was admitted to the Philippine Bar on January 21, 1955. However, subsequent to his admission, he committed acts of misconduct as a notary public, displaying behavior deemed unworthy of a legal professional.
2. **Disbarment Order:** On May 29, 1959, the Supreme Court ordered the disbarment of Atty. Rusiana, removing him from the Roll of Attorneys due to the aforementioned misconduct.
3. **Petition for Reinstatement:** Following his disbarment, Atty. Rusiana intermittently filed petitions for re-admission to the bar. These petitions were supported by resolutions from various local entities in Cebu attesting to his good conduct post-disbarment.
4. **Court’s Objective:** In reviewing applications for reinstatement, the Court’s sole objective is to determine if the disbarred attorney has successfully rehabilitated their character, thereby justifying readmission to a trusted profession.
5. **Initial Petition Denials:** The initial petitions filed by Atty. Rusiana for reinstatement were denied by the Supreme Court.
6. **June 13, 1972 Petition:** In 1972, Atty. Rusiana filed a verified petition for reinstatement, providing proofs of honesty and integrity, character testimonials, and clearances from judicial and law enforcement bodies.
7. **July 18, 1972 Hearing:** A hearing on the petition for reinstatement was conducted, during which various certifications attesting to his improved moral character were presented.
8. **Supreme Court Resolution (July 20, 1972):** The Court, noting his prolonged disbarment, improvement in conduct, and assurances for future ethical practice, resolved that Atty. Rusiana could be reinstated upon completing certain conditions.
9. **Reinstatement Conditions:** These conditions required Atty. Rusiana to enroll in and pass fourth-year review classes at a recognized law school to guarantee his current knowledge and ability to practice law effectively.
10. **Compliance with Conditions:** Atty. Rusiana complied with the conditions by attending and passing review classes at the Gullas Law School, University of the Visayas, as evidenced by sworn certificates from his professors and affirmations from the school’s Registrar and Dean.
**Issues:**
1. **Rehabilitation and Character Assessment:** Whether Atty. Rusiana had sufficiently rehabilitated his character and could demonstrate integrity and competence to be readmitted to the Bar.
2. **Adequacy of Legal Knowledge:** Whether Atty. Rusiana’s legal knowledge met current standards given changes in law since his original disbarment.
**Court’s Decision:**
1. **Character Rehabilitation:** The Court found that Atty. Rusiana had successfully rehabilitated his character. Testimonies and certifications provided substantial evidence of his good conduct and moral integrity over the years following his disbarment.
2. **Updated Legal Competence:** Atty. Rusiana’s completion of the required legal education and review classes offered assurance of his legal competence. The Court accepted these as fulfillment of the condition imposed in their previous resolution.
3. **Reinstatement Order:** In accordance with the July 20, 1972 resolution, Atty. Rusiana was granted permission to take the lawyer’s oath again and sign the Roll of Attorneys after paying requisite fees, thereby reinstating him as a member of the Philippine Bar.
**Doctrine:**
The case reiterates the doctrine that disbarred attorneys seeking reinstatement must prove through clear and positive evidence that they have rehabilitated their moral character and possess the legal competence expected of an attorney. It emphasizes the Court’s role in ensuring that the practice of law remains an office of trust.
**Class Notes:**
– **Rehabilitation of Character:** Essential for reinstatement of disbarred attorneys; involves demonstrating good conduct and integrity over a significant period.
– **Competency Requirements:** Reflects the need for reinstated attorneys to show updated knowledge of current laws and legal principles.
– **Process for Reinstatement:** May involve conditions such as additional legal education or review classes.
**Historical Background:**
The case reflects a period in Philippine legal history where there was significant emphasis on moral character as a cornerstone of legal practice. The decision illustrates the evolving approach toward disciplinary actions and rehabilitation within the legal profession, aligning with broader movements towards integrity and public trust in legal institutions during mid-20th century Philippines.
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