FACTS:

The case involves a disbarment complaint filed by Atty. Edita Noe-Lacsamana against Atty. Yolando F. Busmente. Noe-Lacsamana alleges that she represented Irene Bides in a civil case in which Busmente represented the defendant, Imelda B. Ulaso. Noe-Lacsamana claims that Ulaso's deed of sale was annulled and that ejectment and falsification cases were filed against Ulaso, with Busmente appearing as counsel. Noe-Lacsamana alleges that Atty. Elizabeth Dela Rosa, who accompanied Ulaso in court, was not a lawyer despite being identified as Busmente's collaborating counsel. Further investigation reveals that Dela Rosa indeed does not have a law license. Busmente argues that Dela Rosa was his paralegal assistant, denies representing Ulaso in the mentioned cases, and claims that his signature on Noe-Lacsamana's Answer was forged. The IBP Commission on Bar Discipline finds Dela Rosa guilty of unauthorized practice of law, representing Ulaso as Busmente's collaborating counsel. The IBP recommends Busmente's suspension for not less than five years, which was reduced to six months by the IBP Board of Governors. Busmente files a motion for reconsideration, but it is denied. The issue in the case is whether Busmente is guilty of assisting Dela Rosa in her illegal practice of law. The Court rules in favor of the IBP, finding Busmente guilty of indirectly assisting Dela Rosa, in violation of Canon 9 of the Code of Professional Responsibility.

ISSUES:

1. Whether Busmente is guilty of directly or indirectly assisting Dela Rosa in her illegal practice of law.

RULING:

1. Yes, Busmente is guilty of directly or indirectly assisting Dela Rosa in her illegal practice of law. The Court ruled that the term "practice of law" implies customarily or habitually holding oneself out to the public as a lawyer for compensation as a source of livelihood or in consideration of his services. Busmente's collaboration with Dela Rosa, where she represented clients as his collaborating counsel, constituted indirect assistance in the unauthorized practice of law. This is in violation of Canon 9 of the Code of Professional Responsibility, which prohibits lawyers from directly or indirectly assisting in the unauthorized practice of law.

PRINCIPLES:

• Canon 9 of the Code of Professional Responsibility states that a lawyer shall not, directly or indirectly, assist in the unauthorized practice of law.

• The term "practice of law" implies customarily or habitually holding oneself out to the public as a lawyer for compensation as a source of livelihood or in consideration of his services.

• Holding oneself out as a lawyer may be shown by acts indicative of that purpose, such as identifying oneself as an attorney, appearing in court in representation of a client, or associating oneself as a partner of a law office for the general practice of law.