2013 Legal and Judicial Ethics, Q5

Atty. Repatriar, a law school classmate, approached you on your 25th Class Reunion, with questions on how he can resume the practice of law in the Philippines. He left the country in 1977 after two (2) years of initial law practice, and migrated to the United States where he was admitted to the practice of law in the State of New York. He asks that you give him a formal legal opinion on his query.
Outline briefly the steps and the supporting legal reasons you would state in your legal opinion on what Atty. Repatriar should do to resume his Philippine practice. (8%)

Quick check

What law allows natural-born Philippine lawyers who acquired foreign citizenship to reacquire Philippine citizenship and resume law practice?

What court has exclusive constitutional authority to grant a petition for readmission to the practice of law in the Philippines?

Which of the following is a mandatory condition precedent before a reacquired citizen lawyer may resume legal practice in the Philippines?

What legal education requirement must a returning lawyer satisfy prior to actively practicing law in Philippine courts?

How does foreign naturalization initially affect a Filipino attorney's privilege to practice law in the Philippines?

Learn more about these topics

1. Dual Citizenship Reacquisition
Under Republic Act No. 9225, also known as the Citizenship Retention and Re-acquisition Act of 2003, natural-born citizens of the Philippines who lost their Philippine citizenship by reason of foreign naturalization are deemed not to have lost their citizenship upon taking the oath of allegiance to the Republic. Reacquisition of Philippine citizenship restores the fundamental prerequisite of citizenship required for the practice of law. However, reacquiring dual citizenship does not automatically confer the immediate right to resume legal practice without complying with additional administrative and judicial conditions established by the Supreme Court.

2. Supreme Court Readmission
The practice of law is a privilege subject to the strict regulatory authority of the Supreme Court under Article VIII of the Constitution. A natural-born lawyer who lost citizenship and subsequently reacquired it under Republic Act No. 9225 must file a formal petition with the Supreme Court for authority to resume the practice of law. The applicant must show continued good moral character, retake the lawyer's oath, pay all required fees, update Integrated Bar of the Philippines dues, and satisfy mandatory continuing legal education requirements before resuming active practice.

3. MCLE Compliance Duty
Under Bar Matter No. 850, all active members of the Philippine Bar are required to comply with Mandatory Continuing Legal Education requirements to ensure they maintain professional competence and stay updated on legal developments. A lawyer returning to practice after decades of residence in a foreign jurisdiction must satisfy MCLE requirements for the applicable compliance periods specified by the Supreme Court. Completing the required MCLE credit hours guarantees that returning practitioners are fully equipped to uphold high ethical and technical standards when representing clients in Philippine courts.

About these questions and answers
The questions reproduced here are the official texts of the Philippine Bar Examinations, published by the Supreme Court. They are reproduced for study purposes.The suggested answers are the author’s own.

They are not official answers, have no connection with the Supreme Court, the Office of the Bar Confidant, or any bar review institution, and are not endorsed by any of them. Official answer keys, where released, should be preferred over anything here.Nothing on this page is legal advice, and reading it creates no lawyer-client relationship. Do not rely on any suggested answer in an actual legal matter. Consult counsel on your own facts.Suggested answers reflect the law and jurisprudence the author considers applicable as of the date shown.

Where a question comes from an earlier examination, the suggested answer applies the law as it now stands, which may differ from the law in force when the question was given, and may therefore differ from what would have been the correct answer at that time. Where the difference is material, the answer notes it.The practice scoring feature measures wording overlap with the suggested answer. It is not a grade, carries no official weight, and says nothing about whether your reasoning is sound.Errors are possible. If you find one, please tell me and I will correct it.Last reviewed: October 2026