G.R. No. I-2 September 30, 1971
IN THE MATTER OF THE PETITIONS TO AFFIRM RIGHT TO PRACTICE LAW AND FOR ISSUANCE OF A DUPLICATE LAWYER’S CERTIFICATE. ANDRES CULANAG alias ATTY. ROSS V. PANGILINAN, petitioner.

FACTS

Andres Culanag, representing himself as “Atty. Ross V. Pangilinan,” filed two petitions with the Supreme Court. The first petition (Misc. Bar-I) sought affirmation of his right to practice law, alleging he was admitted to the Bar on January 18, 1954, and that his duplicate lawyer’s certificate and law diploma were confiscated by the National Bureau of Investigation (NBI). The second petition (Misc. Bar-2) prayed for the issuance of a duplicate lawyer’s certificate, claiming his original was lost in a typhoon. The Solicitor General and the NBI Director filed oppositions, asserting that the petitioner was an impostor whose real name was Andres Culanag, not a lawyer, and that he had been previously convicted for falsification for assuming the identity of Ross V. Pangilinan and had served a prison sentence.
The real Atty. Ross V. Pangilinan intervened, confirming he was not the petitioner, that he possessed his original lawyer’s certificate, and that Andres Culanag was a fraud who had only finished second-year high school. The record revealed Culanag had filed multiple civil cases in different courts using varying addresses to recover the confiscated documents, and had moved to withdraw these cases and his Supreme Court petitions upon sensing the Court’s discovery of his deceit. He also sought postponements of hearings, including one via a telegraphic motion claiming illness.

ISSUE

Whether the Supreme Court should grant the petitions of Andres Culanag to affirm his right to practice law and issue him a duplicate lawyer’s certificate.

RULING

The Supreme Court dismissed both petitions. The legal logic is grounded in the Court’s inherent power to regulate the practice of law and protect the integrity of the legal profession. The practice of law is a privilege reserved for individuals who have proven their qualifications, good moral character, and compliance with statutory requirements. Culanag’s petitions were based on a false identity and fraudulent claims of being a member of the Bar. The overwhelming evidence from the Solicitor General, the NBI, and the verified comment of the genuine Ross V. Pangilinan established that Culanag was an impostor with a criminal record for falsification related to this very impersonation. His conduct in filing multiple, inconsistent court actions and his attempts to withdraw his petitions when exposed demonstrated a pattern of deceit aimed at misleading the judiciary.
The Court cannot affirm a right to practice law that does not exist, nor issue a certificate to a non-lawyer. To do so would undermine public confidence in the legal system and endanger the welfare of clients. Consequently, the Court ordered the NBI to deliver the confiscated documents bearing Pangilinan’s name to the Supreme Court for safekeeping. Furthermore, the Court directed Culanag to show cause why he should not be punished for contempt for filing false petitions and instructed various prosecutorial offices to institute appropriate criminal proceedings against him for his fraudulent actions.