SC allows 2022 Bar passer to take oath despite civil status issue

A 2022 Bar passer has been allowed by the Supreme Court to take the Lawyer’s Oath and sign the Roll of Attorneys after resolving issues related to her civil status.

In an 8 July 2025 decision released recently, the Court en banc granted the petition of Angeli Newin Agraam, allowing her to take her oath with the civil status “single” while she awaits the recognition of her Canadian husband’s foreign divorce by a Philippine court.

The ruling came after Agraam was able to submit her marriage certificate and explain that she could not yet secure a Philippine Statistics Authority (PSA) marriage certificate, as her husband’s prior foreign divorce from a Filipino citizen has not been recognized locally.

The High Court ruled that the updating of Agraam’s civil status records should not bar her admission into the legal profession.

“The Court is hard-pressed to find any knowable benefit in preventing a Bar passer from completing her admission into the legal profession on the sole basis of an updating of records which is, while prudent, not entirely central to the requisites of admission to the Bar as to prevent a person from admission thereto,” the ruling penned by Associate Justice Alfredo Benjamin Caguioa said.

The Court also noted that its own guidance shows that it is ultimately up to a female lawyer whether to reflect her married status in the Office of the Bar Confidant and the Roll of Attorneys.

Earlier, Agraam had been barred from taking the Lawyer’s Oath and signing the Roll of Attorneys due to the pending submission of her PSA Certificate of Marriage. Records showed that she and her husband were married in Canada, and she had indicated in her Bar examination application that she was married.

However, the PSA could not issue her marriage certificate because her husband’s previous marriage remained valid in its records, pending judicial recognition of his foreign divorce.

This prompted Agraam to petition the Court to allow her to change her civil status to “single” so she could formally join the legal profession. The Office of the Bar Confidant had recommended that the petition be denied.

In its ruling, the High Court allowed Agraam to take her oath and sign the Roll of Attorneys using the civil status “single,” while directing her to update her records once her husband’s foreign divorce is recognized by a Philippine court.

The Court said that the accurate reflection of her civil status does not affect her ability to fulfill her duties as a lawyer. It further noted that her inability to obtain a marriage certificate was not due to a bigamous or invalid marriage.

“To impute malice, on petitioner’s inability to accurately reflect her married status in view of the nonrecognition of her husband’s foreign divorce, is to penalize petitioner on account of a requirement that, in the larger context of the facts of the case, is a remediable technical requirement,” the ruling said.

The Court added that it is “severely speculative” to impute malice on Agraam, stressing that she was transparent about her civil status despite the complicated legal process surrounding her husband’s foreign divorce.