2018 Legal and Judicial Ethics, Q2

In a complaint filed before the Integrated Bar of the Philippines (IBP) against Atty. Cirilo Celis, a senior citizen, it was shown that: a) he failed to pay his IBP dues for six (6) years; b) he indicated uniformly in his pleadings for three (3) consecutive years “IBP Muntinlupa OR No. 12345” as proof of payment of his IBP fees; and c) he did not indicate any Professional Tax Receipt number to prove payment of his professional dues.
In his defense, Atty. Celis alleged that he is only engaged in a “limited” law practice, and his principal occupation, as disclosed in his income tax return, is that of a farmer of a 30-hectare orchard and pineapple farm in Camarines Sur. He also claimed that he believed in good faith that, as a senior citizen, he was exempt from payment of taxes, such as income tax, under Republic Act No. 7432 which grants senior citizens “exemption from the payment of individual income taxes provided that their annual taxable income does not exceed the poverty level as determined by the NEDA for that year.”
As a member of the IBP Board of Governors, decide on the following:
(a) the validity of his claim that, being engaged in a limited practice of law and being a senior citizen who is exempt from the payment of taxes, he is not required to pay his IBP and professional dues; (2.5%)
(b) the obligations, if any, under the Rules of Court and the Code of Professional Responsibility that Atty. Celis may have violated. (2.5%)

Quick check

Are senior citizens exempt from paying Integrated Bar of the Philippines (IBP) membership dues under Republic Act No. 7432?

Does engaging in a 'limited' law practice exempt an attorney from paying annual IBP membership dues?

What ethical violation is committed when an attorney repeatedly uses a fake IBP receipt number in pleadings?

What mandatory information must a practicing lawyer indicate on all pleadings filed before Philippine courts?

What ruling established that senior citizen tax exemptions under Republic Act No. 7432 do not cover IBP dues?

Learn more about these topics

1. IBP Dues Nature
Under Santos v. Llamas, membership dues in the Integrated Bar of the Philippines are regulatory fees exacted pursuant to the court's police power to regulate the legal profession. They are not taxes. Consequently, senior citizen tax exemptions under Republic Act No. 7432 apply exclusively to national individual income taxes and do not extend to IBP membership dues. Furthermore, engaging in a limited practice of law or pursuing agriculture as a principal occupation does not relieve a lawyer from the mandatory statutory obligation to pay annual IBP membership dues as a condition for maintaining good standing in the Bar.

2. Misrepresentation in Pleadings
Under the Code of Professional Responsibility and Accountability (CPRA), a lawyer owes complete candor, fairness, and honesty to the court. Repeatedly indicating a false or fictitious IBP official receipt number in court pleadings for three consecutive years constitutes deliberate misrepresentation and gross deceit. Such fraudulent practice deceives the court, violates the attorney's oath, and undermines the integrity of judicial proceedings. Lawyers are strictly prohibited from committing any falsehood or perverting procedural rules to conceal non-payment of mandatory bar dues or to mislead judicial tribunals.

3. PTR Pleading Requirement
Under Rule 7, Section 3 of the Rules of Court and administrative issuances of the Supreme Court, a practicing lawyer is required to indicate his Professional Tax Receipt (PTR) number, IBP official receipt number or roll number, and MCLE compliance details on all pleadings filed in court. Failure to indicate the PTR number violates mandatory court pleading requirements and constitutes an administrative infraction. Practice of law is a privilege conditioned upon continuous compliance with both regulatory fee payments and ethical standards imposed by the Supreme Court.

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