FACTS:

Complainant Tan submitted a comment on the fitness of respondent Sabandal to be admitted to the Philippine Bar. Another comment was submitted insisting on "serious moral questions" surrounding respondent. A decision was made in Civil Case 3747, finding respondent administratively liable and ordering the cancellation of his title and the reversion of the land to the State. A resolution denied reconsideration of a previous resolution in view of the pending civil case and required respondent to comment on the decision. It was noted that respondent's practice of law was previously suspended but a petition to suspend his practice was denied. A motion was treated as a separate administrative case against respondent and he was required to comment. Both complainant and respondent have filed their respective rejoinders.

ISSUES:

1. Whether personal forgiveness is enough basis to exculpate and obliterate the cases against the respondent.

2. Whether the termination of Civil Case No. 3747 is proof of the respondent's sincere reformation and repentance.

RULING:

1. The Court denied the respondent's plea to be allowed to take the Lawyer's Oath. It was held that the personal forgiveness of one complainant and the termination of Civil Case No. 3747 are not sufficient grounds for exculpating the respondent. The Court considered the gravity of the civil case against the respondent, wherein he procured a certificate of free patent over a parcel of land belonging to the public domain and used it as security for a mortgage to obtain a loan. The respondent was declared in default and the controversy was eventually settled by a compromise. The Court concluded that the personal forgiveness and termination of the civil case do not improve the respondent's moral fitness to become a member of the Philippine Bar.

PRINCIPLES:

• Finality of court resolutions that are already res judicata cannot be changed or amended by the personal moods or dispositions of the parties.

• The personal forgiveness of a complainant is not enough basis to exculpate and obliterate a case.

• Termination of a civil case and a show of contrition and willingness to reform are not sufficient grounds for admission to the Philippine Bar, especially when the case involves grave misconduct or offense.

• The practice of law is not a matter of right but a privilege bestowed upon individuals who are not only learned in the law but also possess good moral character.

• Good moral character includes common honesty.

• No moral qualification for bar membership is more important than truthfulness or candor.