​IN RE GARCIA

ISSUE:  Whether or not a treaty may enable Garcia to practice  law in the Philippines? 

FACTS:  Arturo E. Garcia, a Filipino citizen, finished a law course in Spain and was  thereafter allowed to practice law. He contends that he is entitled to practice law in  the Philippines without submitting himself to the bar examinations under the  Treaty of Academic Degree and the Exercise of Professions between the  Philippines and Spain. 

DECISION:  No. The treaty only applies to Filipino citizens  desiring to practice their profession in Spain and  Spanish citizens desiring to practice their profession  in the Philippines. 

RATIO DECIDENDI:  Since, Garcia is a Filipino citizen, he is therefore subject to the laws of his own country.  The executive department may not encroach upon the constitutional prerogative of the  Supreme Court to promulgate rules for admission to the practice of law in the Philippines.