a. Filipino citizenship given to non-lawyer employees of b. Satisfaction of the MCLE a law firm requirement for provision of MCLE number which will be In the instant case, being not one of indicated in his pleadings in the enumerated exceptions provided court for by the CPR, allowing such c. Payment of IBP fees division of legal fees would be a violation of the CPR. 2. Membership to the IBP is not in violation of ones freedom to 4. Canon 11 of the CPR provides that a associate or corollary right not to lawyer must observe and maintain associate. The practice of law is respect due to the courts and clothed with public interest; judicial officers and should insist that therefore, requires States others conduct in the same. The regulation. A lawyer becomes a NLRC is not merely an administrative member of the Bar. The case of Atty. body. It is also given quasi-judicial Edillion differentiates Integration of functions for cases and the Bar from bar associations controversies arising from organized by individual lawyers. The employee-employer relationship. Court said that an integrated bar The NLRC having quasi-judicial is state-organized association, to functions may also be considered as which every lawyer must belong the a court and therefore, the Code of moment he/she passed the Bar. In Professional Responsibility may associations organized by individual apply when lawyers appear as lawyers themselves, membership in counsel for cases before it. Further, which is voluntary. Therefore, under the CPR, lawyers should not compulsory membership is not use abusive languages towards the violative of ones freedom to courts and any allegations and associate because IBP membership inconsistencies pertaining to a is an incidental effect of being given decision of a judge must likewise be the privilege of practicing the legal presented with sufficient evidences profession. to question the decisions validity. Therefore, Atty. Dayan is 3. Canon 9 of the CPR provides that a administratively liable for violation lawyer shall not directly or indirectly of the CPR assist in the unauthorized practice of law. In conjunction to this, it is also 5. Claveria cannot be exempted from provided under this Canon that a paying her IBP dues because lawyer shall give, share or divide payment of the same is incidental legal fees to non-lawyers except on duty to being a member of the Bar. the following circumstances: Moreover, she should not be a. When there had been a pre- exempted from compliance with the existing agreement between a MCLE requirement, as the same is partner or associate that upon needed for every lawyer for as long the latters dear, a certain as they are to practice their amount of money shall be given profession. to the latters estate or to the person in the agreement 6. It is the duty of lawyers to arrange b. When a lawyer undertakes to clients to avoid suits and arrive at an continue work on a case of a amicable settlement. However in the deceased lawyer instant case the compromise agreements entered upon by Barrion with the clients of Yanga, without the There being no evidence of neglect latters consent is a violation of the of duty, Barrion cannot validly CPR. The CPR provides that lawyers encroach upon the employment of must not encroach with the clients of Yanga by entering into a another lawyer with the exception compromise agreement without the that their current lawyer has become latters consent. Thus, Barrions acts neglectful of his duties to the are violative of the CPR. detriment of the case and his client.