Legal Counseling.docx

LECTURE ON LEGAL COUNSELLING

x------------------------------PRIVELEGE------------------------------x In Re: Dacanay, B.M NO. 1678, December 17, 2007 FACTS: Petitioner was admitted to the Philippine bar in March 1960. He practiced law until he migrated to Canada in December 1998 to seek medical attention for his ailments. He subsequently applied for Canadian citizenship to avail of Canada’s free medical aid program. His application was approved and he became a Canadian citizen in May 2004.On July 14, 2006, pursuant to Republic Act (RA) 9225 (Citizenship Retention and Re-Acquisition Act of 2003), petitioner reacquired his Philippine citizenship. On that day, he took his oath of allegiance as a Filipino citizen before the Philippine Consulate General in Toronto, Canada. Thereafter, he returned to the Philippines and now intends to resume his law practice. ISSUE: WON petitioner may still resume practice? YES HELD: Section 2, Rule 138 of the Rules of Court provides an applicant for admission to the bar be a citizen of the Philippines, at least twenty-one years of age, of good moral character and a resident of the Philippines.5 He must also produce before this Court satisfactory evidence of good moral character and that no charges against him, involving moral turpitude, have been filed or are pending in any court in the Philippines. Since Filipino citizenship is a requirement for admission to the bar, loss thereof terminates membership in the Philippine bar and, consequently, the privilege to engage in the practice of law. In other words, the loss of Filipino citizenship ipso jure terminates the privilege to practice law in the Philippines. The practice of law is a privilege denied to foreigners. The exception is when Filipino citizenship is lost by reason of naturalization as a citizen of another country but subsequently reacquired pursuant to RA 9225. This is because “all Philippine citizens who become citizens of another country shall be deemed not to have lost their Philippine citizenship under the conditions of [RA 9225].” Therefore, a Filipino lawyer who becomes a citizen of another country is deemed never to have lost his Philippine citizenship if he reacquires it in accordance with RA 9225.Before he can resume his law practice, he must first secure from this Court the authority to do so, conditioned on: of the updating and payment of IBP membership dues; of the payment of professional tax; of the completion of at least 36 credit hours of mandatory continuing legal education; this is specially significant to refresh the applicant/petitioner’s knowledge of Philippine laws and update him of legal developments and for the retaking of the lawyer’s oath. DECISION: GRANTED.

LECTURE ON LEGAL COUNSELLING

KHAN V SIMBILLO A.C. No.5299

August 19, 2003

FACTS: Respondent, RizalinoSimbillo, published advertisements on different news publications on different dates regarding his services as an “Annulment of Marriage specialist”. Petitioner, Ismael Khan, in his capacity as an assistant court administrator and chief of the public information office filed an administrative complaint against respondent for improper advertising and solicitations of his legal services, in violations of Rule 2.03 and Rule 3.01 of the Code of Professional Responsibility and Rule 138, Section 27 of the Rules of Court. Respondent admitted acts imputed to him but argued that his acts for advertising and solicitation are not prohibited acts. Respondent prays for his acquittal because of the court’s ruling that advertisement of legal services offered by a lawyer is not contrary to law, public policy and public order. The Integrated Bar of the Philippines (IBP) investigated the acts of the petitioner and found the respondent guilty of the administrative complaint filed by the petitioner. ISSUE: W/N petitioners published advertisement is a valid act and does not violate the Rules of Court or the Code of Professional Responsibility. RULING: Respondent Simbillo is SUSPENDED from the practice of law for one year. NO (not valid act of advertising) Pursuant to Rule 2.03 and Rule 3.01 of the Code of Professional Responsibility and Rule 138, Section 27 of the Rules of Court, the practice of law is not a business but a profession which duty to public service, not money, is the prime consideration. The duty to public service and to the administration of justice should be the primary consideration of lawyers. Elements that distinguish the legal profession from a business: 1. A duty of public service, of which the emolument is a by-product, and in which one may attain the highest eminence without making much money; 2. A relation as an “officer of the court” to the administration of justice involving thorough sincerity, integrity and reliability; 3. A relation to clients in the highest degree of fiduciary; 4. A relation to colleagues at the bar characterized by candor, fairness, and unwillingness to resort to current business methods of advertising and encroachment on their practice, or dealing directly with their clients.

LECTURE ON LEGAL COUNSELLING

In advertising himself as an “Annulment of Marriage Specialist” he undermines to sanctity of marriage. A lawyer may not properly publish biographical and informative data in a daily paper, magazine, trade journal or society program. A lawyer is not permitted to publish any contents which are likely to deceive or injure the public or the bar, or to lower dignity or standing of the profession. x------------------------------QUALIFICATIONS------------------------------x In the matter of the Admission to the Bar and Oath-Taking of Argosino B.M. 712 July 13, 1995 FACTS: On February 4, 1992 ,Argosino, together with 13 others, was charged with the crime of homicide in connection with the death of one Raul Camaligan. The death of Camaligan stemmed from the affliction of severe physical injuries upon him in course of "hazing" conducted as part of the university fraternity initiation rites. On February 11, 1993, the accused were consequently sentenced to suffer imprisonment for a period ranging from two (2) years, four (4) months and one (1) day to four (4) years. Eleven (11) days later, Mr. Argosino and his colleagues filed an application for probation with the lower court. The application was granted on June 18 1993. The period of probation was set at two (2) years, counted from the probationer's initial report to the probation officer assigned to supervise him. Less than a month later, Argosino filed a petition to take the bar exam. He was allowed and he passed the exam, but was not allowed to take the lawyer's oath of office. On April 15, 1994, Argosino filed a petition to allow him to take the attorney's oath and be admitted to the practice of law. He averred that his probation period had been terminated. It is noted that his probation period did not last for more than 10 months. ISSUE: Whether Argosino should be allowed to take the oath of attorney and be admitted to the practice of law HELD: Mr. Argosino must submit to this Court evidence that he may now be regarded as complying with the requirement of good moral character imposed upon those who are seeking admission to the bar. He should show to the Court how he has tried to make up for the senseless killing of a helpless student to the family of the deceased student and to the community at large. In short, he must show evidence that he is a different person now, that he has become morally fit for admission to the profession of law. He is already directed to inform the Court, by appropriate written manifestation, of the names of the parents or brothers and sisters of Camaligan from notice.

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IN RE: ARGOSINO 270 SCRA 26

03/19/1997

FACTS: This is a matter for admission to the bar and oath taking of a successful bar applicant. Petitioner Al Caparros Argosino was previously involved with hazing which caused the death of Raul Camaligan a neophyte during fraternity initiation rites but he was convicted for Reckless Imprudence Resulting in Homicide. He was sentenced with 2 years and 4 months ofimprisonment where he applied a probation thereafter which was approved and granted by the court. He took the bar exam and passed but was not allowed to take the oath. He filed for a petition to allow him to take the lawyer’s oath of office and to admit him to the practice of law averring that his probation was already terminated. The court note that he spent only 10 months of the probation period before it was terminated. ISSUE: Whether or not Al Argosino may take the lawyer’s oath office and admit him to the practice of law. HELD: The practice of law is a privilege granted only to those who possess the STRICT, INTELLECTUAL and MORAL QUALIFICATIONS required of lawyers who are instruments in the effective and efficient administration of justice. The court upheld the principle of maintaining the good moral character of all Bar members, keeping in mind that such is of greater importance so far as the general public and the proper administration of justice are concerned. Hence he was asked by the court to produce evidence that would certify that he has reformed and has become a responsible member of the community through sworn statements of individuals who have a good reputation for truth and who have actually known Mr. Argosino for a significant period of time to certify that he is morally fit to the admission of the law profession. The petitioner is then allowed to take the lawyer’s oath, sign the Roll of Attorney’s and thereafter to practice the legal profession. x------------------------------APPEARANCE OF NON-LAWYERS------------------------------x RULE 138-A Law Student Practice Rule Section 1. Conditions for student practice. — A law student who has successfully completed his 3rd year of the regular four-year prescribed law curriculum and is enrolled in a recognized law school's clinical legal education program approved by the Supreme Court, may appear without compensation in any civil, criminal or administrative case before any trial court, tribunal, board or officer, to represent indigent clients accepted by the legal clinic of the law school. Section 2. Appearance. — The appearance of the law student authorized by this rule, shall be under the direct supervision and control of a member of the

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Integrated Bar of the Philippines duly accredited by the law school. Any and all pleadings, motions, briefs, memoranda or other papers to be filed, must be signed by the supervising attorney for and in behalf of the legal clinic. Section 3. Privileged communications. — The Rules safeguarding privileged communications between attorney and client shall apply to similar communications made to or received by the law student, acting for the legal clinic. Section 4. Standards of conduct and supervision. — The law student shall comply with the standards of professional conduct governing members of the Bar. Failure of an attorney to provide adequate supervision of student practice may be a ground for disciplinary action. (Circular No. 19, dated December 19, 1986). Non-lawyers who may be authorized to appear in court/admin: 1. Cases before the MTC: Party to the litigation, in person OR through an agent or friend or appointed by him for that purpose (Sec. 34, Rule 138, RRC) 2. Before any other court: Party to the litigation, in person (Ibid.) 3. Criminal case before the MTC in a locality where a duly licensed member of the Bar is not available: the judge may appoint a non-lawyer who is: 1. resident of the province 2. of good repute for probity and ability to aid the accused in his defense (Rule 116, Sec. 7, RRC). 4. Legal Aid Program – A senior law student, who is enrolled in a recognized law school’s clinical education program approved by the supreme Court may appear before any court without compensation, to represent indigent clients, accepted by the Legal Clinic of the law school. The student shall be under the direct supervision and control of an IBP member duly accredited by the law school. 5. Under the Labor code, non-lawyers may appear before the NLRC or any Labor Arbiter, if 1. they represent themselves, or if 2. they represent their organization or members thereof (Art 222, PO 442, as amended). 6. Under the Cadastral Act, a non-lawyer can represent a claimant before the Cadastral Court (Act no. 2259, Sec. 9).

PROCEEDINGS WHERE LAWYERS ARE PROHIBITED FROM APPEARING Small Claims Cases Rules of Procedure for Small Claims Cases, AM No.08-8-7, Sec. 17. Appearance of Attorneys Not Allowed. — No attorney shall appear in behalf of or represent a party at the hearing, unless the attorney is the plaintiff or defendant. Katarungang Pambarangay

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RA 7160, Sec. 415. In all katarungang pambarangay proceedings the parties must appear in person without the assistance of counsel or representative except for minors and incompetents who may be assisted by their next of kin who are not lawyers. SANCTIONS FOR PRACTICE OR APPEARANCE WITHOUT AUTHORITY (1) Lawyers without authority (2) Persons not lawyers Shari’a Bar passers are not full-fledged Philippine Bar members so they may only practice before Shari’a courts. Both are counselors, but only the latter is an “attorney.” [Alawi v. Alauya, (1997)] REMEDIES AGAINST UNAUTHORIZED PRACTICE (1) Petition for Injunction (2) Declaratory Relief (3) Contempt of Court (4) Disqualification and complaints for disbarment; (5) Criminal complaint for estafa against the person who falsely represented himself as a lawyer to the damage of another

x---------------SANCTIONS FOR PRACTICE W/O AUTHORITY---------------x IN RE: PETITION TO SIGN IN THE ROLL OF ATTORNEYS MICHAEL A. MEDADO FACTS: Michael A. Medado passed the Philippine bar exams in 1979. On 7 May 1980, he took the Attorney’s Oath at the PICC. He was scheduled to sign in the Roll of Attorneys on 13 May 1980, but failed to do so allegedly because he had misplaced the Notice to Sign the Roll of Attorneys. Several years later, while rummaging through his things, he found said Notice. He then realized that he had not signed in the roll, and that what he had signed at the entrance of the PICC was probably just an attendance record. He thought that since he already took the oath, the signing of the Roll of Attorneys was not as important. The matter of signing in the Roll of Attorneys was subsequently forgotten. In 2005, when Medado attended MCLE seminars, he was required to provide his roll number for his MCLE compliances to be credited. Not having signed in the Roll of Attorneys, he was unable to provide his roll number. About seven years later, in 2012, Medado filed the instant Petition, praying that he be allowed to sign in the Roll of Attorneys. Medado justifies this lapse by

LECTURE ON LEGAL COUNSELLING

characterizing his acts as “neither willful nor intentional but based on a mistaken belief and an honest error of judgment. The Office of the Bar Confidant recommended that the instant petition be denied for petitioner’s gross negligence, gross misconduct and utter lack of merit, saying that petitioner could offer no valid justification for his negligence in signing in the Roll of Attorneys. ISSUE: Whether or not petitioner may be allowed to sign the Roll of Attorneys. RULING: Yes, the Supreme Court granted the petition subject to the payment of a fine and the imposition of a penalty equivalent to suspension from the practice of law. Not allowing Medado to sign in the Roll of Attorneys would be akin to imposing upon him the ultimate penalty of disbarment, a penalty reserved for the most serious ethical transgressions. In this case, said action is not warranted. The Court considered Medado’s demonstration of good faith in filing the petition himself, albeit after the passage of more than 30 years; that he has shown that he possesses the character required to be a member of the Philippine Bar; and that he appears to have been a competent and able legal practitioner, having held various positions at different firms and companies. However, Medado is not free from all liability for his years of inaction. A mistake of law cannot be utilized as a lawful justification, because everyone is presumed to know the law and its consequences. Medado may have at first operated under an honest mistake of fact when he thought that what he had signed at the PICC entrance before the oath-taking was already the Roll of Attorneys. However, the moment he realized that what he had signed was just an attendance record, he could no longer claim an honest mistake of fact as a valid justification. At that point, he should have known that he was not a full-fledged member of the Philippine Bar, as it was the act of signing therein that would have made him so. When, in spite of this knowledge, he chose to continue practicing law, he willfully engaged in the unauthorized practice of law. Knowingly engaging in unauthorized practice of law likewise transgresses Canon 9 of the Code of Professional Responsibility. At the heart of Canon 9 is the lawyer’s duty to prevent the unauthorized practice of law. This duty likewise applies to law students and Bar candidates. As aspiring members of the Bar, they are bound to conduct themselves in accordance with the ethical standards of the legal profession.

LECTURE ON LEGAL COUNSELLING

Medado cannot be suspended as he is not yet a full-fledged lawyer. However, the Court imposed upon him a penalty akin to suspension by allowing him to sign in the Roll of Attorneys one (1) year after receipt of the Resolution. He was also made to pay a fine of P32,000. Also, during the one-year period, petitioner was not allowed to engage in the practice of law.

Rey Vargas et al v. Atty. Michael Ignes Facts: Koronadal Water District (KWD) is a government owned and controlled corporation (GOCC). Atty. Michael Ignes was hired as private legal counsel for 1 year effective April 17, 2006 with the consent of the Office of Government Corporate Counsel (OGCC) and Commission on Audit (COA). Controversy erupted when 2 different groups, the Dela Pea Board and Yaphockun Board, simultaneously claimed to be the legitimate Board of Directors of KWD. The Dela Pea Board adopted Resolution 9 appointing respondents Atty. Rodolfo Viajar Jr. and Atty. Leonard Mann as private collaborating counsels for all cases of KWD and its Board under the supervision of Atty. Ignes. On February 16, 2007 the OGCC approved the retainership contract of Atty. Benjamin Cunanan as new legal counsel of KWD. This was pursuant to the Local Water Utilities Administration”s confirmation that the Yaphockun Board was the new board and that the latter requested for new counsel. In addition, it stated that the contract of Atty. Ignes expired on January 14, 2007.4 Still, the following cases were filed by Attys. Ignes, Viajar and Mann: Feb. 9 2007 Indirect Contempt of Court: KWD represented by its Gen. Manager Eleanor Gomba v. Efren Cabucay Feb. 19, 2007 Civil Case for Injunction and Damages: KWD represented by its Gen. Manager Eleanor Gomba v. Rey Vargas Mar. 9, 2007 Supplemental Complaint for the previous case As a result, the complainants filed a disbarment case before the IBP Commission on Bar Discipline (CBD). The IBP Board of Governors dismissed the

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disbarment case. The Investigating Commissioner recommended that the case against Atty. Ignes be dismissed for lack of merit holding that he was unaware of the pre-termination of his contract when he filed pleadings in the abovementioned cases. As to Attys. Viajar, Mann and Nadua, they were fined P 5,000 each for failing to secure the conformity of the OGCC and COA to their employment as collaborating counsels. Hence, this petition for review. Issues: W/N the respondents willfully appeared as counsel for KWD without legal authority and if yes, are administratively liable for doing so. Held/Ratio: YES. Section 3 of Memorandum Circular No. 9 enjoins GOCCs from employing private lawyers/firms from handling their cases and legal matters but under exceptional circumstances may do so provided, The written conformity and acquiescence of the Solicitor General or the Government Corporate Counsel, as the case may be AND b. The written concurrence of the COA shall first be secured before the hiring of a private lawyer/firm. Despite admitting to be aware of the existence of MC 9 requiring indispensible conditions before a GOCC can hire private counsel and that non-compliance with them would render said private counsel no authority to file a case in behalf of a GOCC, they signed pleadings and voluntarily represented themselves as counsels of KWD. Also, the respondents” authority as counsel had already been raised in the previous civil cases by virtue of an urgent motion to disqualify KWD counsels dated Feb 21, 2007 and even during the hearing 2 days later. Even if they claim that their professional fees were not paid from the public coffers of KWD, it is clear that they appeared as counsels of KWD without authority and not merely as counsel of the Dela Pea Board and KWD personnel in their private suits as claimed as one of their defenses. For Atty. John Nadua: Only the 4th Whereas Clause of Res. No. 9 partly stated that he and Atty. Ignes “presently stand as KWD legal counsels.” No proof that COA and OGCC approved his engagement. For Attys. Viajar and Mann: Although Resolution 9 granted them authority to act as collaborating counsels of KWD, it had no approval from the OGCC and COA. For Atty. Ignes: Although the OGCC and COA approved his retainership contract for 1 year effective April 17, 2006, he appeared as counsel of KWD without authority when it expired. Even assuming that he was not notified

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of the pre-termination of his contract, records prove that he continued representing KWD even after April 17, 2007. 5 A lawyer appearing after his authority as counsel has expired is also appearance without authority. Disbarment should not be decreed where any less severe such as reprimand, suspension or fine would accomplish the end desired. Attys. Ignes, Mann, Viajar and Nadua are found guilty of appearing as attorneys without authority to do so and fined P5,000 each and are sternly warned that a similar offense in the future will be dealt with more severely.

Philippine Association of Free Labor Unions (PAFLU), Enrique Entila and Victoriano Tenazas vs. Binalbagan Isabela Sugar Company, Court of Industrial Relations and Quintin Muning

1. 1.

1. a.

FACTS: COURT OF INDUSTRIAL RELATIONS ORDERED REINSTATEMENT WITH BACKWAGES FOR ENTILA AND TENAZAS. Cipriano Cid & Associates, counsel of Entila and Tenazas filed a notice of attorney's lien equivalent to 30% of the total backwages. i. Entila and Tenazas filed manifestation indicating their non-objection to an award of attorney's fees for 25% of their backwages ii. Quentin Muning filed a "Petition for the Award of Services Rendered" equivalent to 20% of the backwages. Opposed by Cipriano Cid & Associates the ground that he is not a lawyer. Court of Industrial Relations awarded 25% of the backwages as compensation for professional services rendered in the case, apportioned as follows: i. Cipriano 10% ii. Quintin Muning 10% iii. Atanacio Pacis 5%

iii. CANON 34: condemns an agreement providing for the division of attorney's fees, whereby a non-lawyer union president is allowed to share in said fees with lawyers 1Sec 5(b) of RA 875 that —No justification for a ruling, that the person representing the party-litigant in the Court of Industrial Relations, even if he is not a lawyer, is entitled to attorney's fees a. Duty and obligation of the Court or Hearing Officer to examine and cross examine witnesses on behalf of the parties and to assist in the orderly presentation of evidence. b. Representation should be exclusively entrusted to duly qualified members of the bar. The permission for a non-member does not entitle the representative to compensation for such representation. Sec 24, Rule 138 Compensation of attorney's agreement as to fees:

LECTURE ON LEGAL COUNSELLING

i. An attorney shall be entitled to have and recover from his client no more than a reasonable compensation for his services. a. Petition to take the Bar Exam in 1960 after failing in the 1959 Bar Examination. b. His uncle, TAPEL, opposed the petition alleging that his nephew is not a person of good moral character for having misrepresented, sometime in 1950, when he was 16 years old, that he was eligible for 3rd year high school by utilizing the school records of his cousin and name-sake, Juan M. Publico. ii. PUBLICO has not completed Grade 4 iii. Tapel instituted an administrative case against his nephew for falsification of school records or credentials. PUBLICO PASSED THE BAR, took the lawyer's oath, and signed the Roll of Attorneys. Legal Officer-Investigator, Ricardo Paras, Jr., investigated and reported: September 1961, Dulcisimo Tapel dropped the complaint on the ground that his witnesses had turned hostile. i. Motion denied, his witnesses had already testified. Recommended PUBLICO’s name to be stricken off the roll of attorneys. i. Respondent falsified his school records ii. Thereby violating the provisions of Sections 5 and 6, Rule 127 of the Rules of Court, which require completion by a bar examinee or candidate of the prescribed courses in elementary, high, pre-law and law school, prior to his admission to the practice of law. 11 years later, PUBLICO filed a Petition for Reinstatement alleging that he had never received, for had he been informed, nor did he have any knowledge of the Resolution of the Court ordering the Bar Division to strike his name from the Roll of Attorneys. He was advised to inquire into the outcome of the disbarment case against him. He resigned from all his positions in public and private offices, and transferred to Manila. Prayed that Court allow reinstatement taking into consideration his exemplary conduct from the time he became a lawyer, his services to the community the numerous awards, resolutions and/'or commendations he received, i. Court denied the Petition. ii. Petitioner moved for reconsideration was denied by the Court for lack of merit. 5th plea avers that his enrollment in Third Year High School in Manila was through the initiative of his uncle, Dulcisimo B. Tapel who accompanied him to school and enrolled him in a grade level above his qualifications in spite of his demonstrations i. Misrepresentation committed was precipitated by his uncle; that being merely 16 year old, he could not be expected to act with discernment as he was still under the influence of his uncle, who later on caused his disbarment ii. No opposition has been filed to any of the petitions. ISSUE: May a non-lawyer recover attorney's fees for legal services rendered?

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Lawyer-client relationship is only possible if one is a lawyer. Since respondent Muning is not one, he cannot establish an attorney-client relationship with Enrique Entila and Victorino Tenezas or with PAFLU, and he cannot, therefore, recover attorney's fees. Public policy demands that legal work in representation of parties litigant should be entrusted only to those possessing tested qualifications, for the ethics of the profession and for the protection of courts, clients and the public. The reasons are that the ethics of the legal profession should not be violated: 1. Acting as an attorney with authority constitutes contempt of court, which is punishable by fine or imprisonment or both, 2. Law will not assist a person to reap the fruits or benefit of an act or an act done in violation of law 3. If were to be allowed to non-lawyers, it would leave the public in hopeless confusion as to whom to consult in case of necessity and also leave the bar in a chaotic condition, aside from the fact that non-lawyers are not amenable to disciplinary measures.

PROHIBITION OR DISQUALIFICATION OF FORMER GOVERNMENT ATTORNEYS Section 7 of R.A. No. 6713 generally provides for the prohibited acts and transactions of public officials and employees. Subsection (b)(2) prohibits them from engaging in the private practice of their profession during their incumbency. As an exception, a public official or employee can engage in the practice of his or her profession under the following conditions: first, the private practice is authorized by the Constitution or by the law; and second, the practice will not conflict or tend to conflict with his or her official functions. PUBLIC OFFICIALS WHO CANNOT PRACTICE LAW OR WITH RESTRICTIONS Absolute Prohibition (1) Judges and other officials as SC employees [Rule 148, Sec. 35] (2) OSG officials and employees (3) Gov’t. prosecutors [People v. Villanueva] (4) Pres., VP, cabinet members, their deputies and assistants, [Const., Art. VIII Sec. 15] (5) Constitutional Commissions Chairmen and Members [Const. Art. IX-A, Sec. 2] (6) Ombudsman and his deputies [Const., Art. IX, Sec. 8, par. 2] (7) All governors, city and municipal mayors [R.A. No. 7160, Sec. 90] (8) Those who, by special law, are prohibited from engaging in the practice of their legal profession

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Relative Prohibition (1) Senators and House of Representatives members (prohibition to appear) [Const. Art VI, Sec. 14] (2) Sanggunian Members [RA No. 7160, Sec. 91] Special Restrictions Retired judges [RA 910, Sec. 1, as amended] A retired justice or judge receiving a pension from the Government cannot act as counsel in any civil case in which the Government or any of its subdivision or agencies is the adverse party or in a criminal case wherein an officer or employee of the Gov’t. is accused of an offense in relation to his office. [R.A. No. 910] LAWYERS AUTHORIZED TO REPRESENT THE GOVERNMENT Any person appointed to appear for the Government of the Philippines shall be allowed to appear in court, subject to pertinent laws.