Thursday, July 27, 2023

Case Digest: Phil Lawyer’s Association vs Agrava 105 Phil 173, G.R. No. L-12426


Phil Lawyer’s Association vs Agrava 105 Phil 173 (1959), G.R. No. L-12426, February 16, 1959

Subject: Basic Legal Ethics


FACTS

On may 27, 1957, respondent Director issued a circular announcing that he had scheduled for June 27, 1957 an examination for the purpose of determining who are qualified to practice as patent attorneys before the Philippines Patent Office, the said examination to cover patent law and jurisprudence and the rules of practice before said office. According to the circular, members of the Philippine Bar, engineers and other persons with sufficient scientific and technical training are qualified to take the said examination. It would appear that heretofore, the respondent Director has been holding similar examinations.

It is the contention of the petitioner Philippine Lawyer's Association that one who has passed the bar examinations and is licensed by the Supreme Court to practice law in the Philippines and who is in good standing, is duly qualified to practice before the Philippines Patent Office, and that consequently, the cat of the respondent Director requiring members of the Philippine Bar in good standing to take and pass an examination given by the Patent Office as a condition precedent to their being allowed to practice before said office, such as representing applicants in the preparation and prosecution of applications for patent, is in excess of his jurisdiction and is in violation of the law.

ISSUE

Whether or not appearance before the patent Office and the preparation and the prosecution of patent applications, constitutes or is included in the practice of law?

RULING

YES. The Supreme Court held that under the present law, members of the Philippine Bar authorized by the Supreme Court to practice law, and in good standing, may practice their profession before the Patent Office, for the reason that much of the business in said office involves the interpretation and determination of the scope and application of the Patent Law and other laws applicable, as well as the presentation of evidence to establish facts involved; that part of the functions of the Patent director are judicial or quasi-judicial, so much so that appeals from his orders and decisions are, under the law, taken to the Supreme Court.

In this case, respondent Director is prohibited from requiring members of the Philippine Bar to submit to an examination or tests and pass the same before being permitted to appear and practice before the Patent Office.

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