Respondent: en Banc

EN BANC
[A.C. No. 1162. August 29, 1975.]
IN RE: VICTORIO D. LANUEVO, former Bar Confidant and Deputy Clerk of

Court , respondent.
[A.C. No. 1163. August 29, 1975.]

IN RE: RAMON E. GALANG, alias ROMAN E. GALANG, 1971 Bar Examinee ,
respondent.
[A.C. No. 1164. August 29, 1975.]
IN RE: HON. BERNARDO PARDO, HON. RAMON PAMATIAN, ATTY. MANUEL
TOMACRUZ, ATTY. MANUEL MONTECILLO, ATTY. FIDEL MANALO and ATTY.
GUILLERMO PABLO, JR., Members, 1971 Bar Examining Committee ,
respondents.
SYNOPSIS
Disbarment proceedings were led against the Bar Con dant, Victorio Lanuevo and a
1971 bar candidate, Ramon Galang, and disciplinary action against ve bar examiners for acts
and omissions committed in the 1971 bar examinations.
Based on a con dential letter from a bar unked, The Supreme Court checked the
records of the 1971 bar examinations. As a result thereof, the grades in ve subjects of an
examinee (Ramon Galang) were found to be charged, which, however, were the properly
initialed and authenticated by each of the examiner concerned. Upon investigation, the Bar
Con dant admitted in his sworn statement having brought back the ve examination
notebooks to the examiners for re-evaluation. In turn, the ve examiners admitted, in their
individual sworn statements, having re-evaluated and re-checked the notebooks involved (all
of which had failing marks) upon the representation made to each of them separately and
individually by the Bar Con dant that examiners were authorized to do so and that the
examinee concerned failed only in his (examiner concerned) particular subject and/or was on
the borderline of passing. On the other hand, Ramon Galang denied any knowledge of the
actuation's of the Bar Confidant.
The Supreme Court, holding that the O ce of the Bar Con dant has absolutely nothing
to do with the re-evaluation or reconsideration of the grades of examinees who fail to make
the passing mark before or after the notebooks are submitted by the examiners and, that,
therefore, the deception made by the Bar Con dant was in violation of the trust and
con dence reposed in him, disbarred the Bar Con dant and ordered his name stricken from
the roll of attorneys.
With respect to respondent Ramon Galang, the Supreme Court likewise disbarred him
because of the highly irregular manner of his passing the bar which was effected through an
authorized re-evaluation of his examination notebooks, and on the ground that he fraudulently
concealed and withheld his pending criminal case for slight physical injuries in all his seven
applications to take the bar examinations which indicates his lack of the requisite attributes
of honesty, probity and good demeanor.
Respondent Bar Examiners were reminded to exercise the greatest or utmost care and
vigilance in the performance of their duties as such.
CD Technologies Asia, Inc. © 2018 cdasiaonline.com

SYLLABUS
1. COURT PERSONNEL AND EMPLOYEES; BAR CONFIDANT; FUNCTIONS AND

DUTIES. — The Bar Con dant is simply the custodian of bar examination notebooks for and in
behalf of the court; hence, any suggestion or request by him for re-evaluation or
reconsideration of the grades of examinees who fail to make the passing mark before or after
the notebooks are submitted by the examiner, is not only presumptuous but also offensive to
the norms of delicacy. His position is primarily con dential as the designation indicates. His
functions in connection with the conduct of the Bar Examinations are de ned and
circumscribed by the Court and must be strictly adhered to.
2. ID.; ID.; ID.; FUNCTION IN CONNECTION WITH BAR EXAMINATIONS. — After the
connected notebooks are submitted to the Bar Con dant by the Examiners, his only function
is to tally the individual grades of every examinee in all subjects taken and thereafter compute
the general average. That done, he will then prepare a comparative data showing the
percentage of passing and failing in relation to a certain average to be submitted to the
Committee and to the Court and on the basis of which the Court will determine the passing
average, whether 75 or 74 or 73, etc. The Bar Confidant has no business evaluating the answer
of the examinees and cannot assume the functions of passing upon the appraisal made by the
Examiner concerned. He is not the over-all Examiner and cannot presume to know better than
the Examiner.
3. SUPREME COURT; JUDICIAL FUNCTION IN ADMITTING BAR CANDIDATES. — The
judicial function of the Supreme Court is admitting candidates to the legal profession, which
necessarily involves the exercise of discretion, requires: (1) previous established rules and
principles; (2) concrete facts whether past or present, affecting determine individuals; and (3)
a decision as to whether these facts are governed by the rules and principles.
4. ID.; ID.; BAR EXAMINATION COMMITTEE. — In the exercise of the judicial function
in admitting bar candidates, the Court acts through a Bar Examination Committee, composed
of a member of the Court who acts as Chairman and eight (8) members of the Bar who act as
examiners in the eight (8) bar subject with one subject assigned to each. Acting as a sort of
liaison o cer between the Court and Bar Chairman, on the one hand, and the individual
members of the Committee, on the other, is the Bar Con dant is at the same time a deputy
clerk of the court.
5. ID.; ID.; ID.; ACTS OF COMMITTEE MUST BE IN ACCORDANCE WITH
ESTABLISHED RULES OF COURT. — Every act of Committee in connection with the exercise of
discretion in the admission of examinees to membership of the Bar must be in accordance
with the established rules of the Court and must always be subject to the nal approval of the
Court.
6. BAR EXAMINATIONS; REQUEST FOR RE-EVALUATION. — Any request for re-
evaluation should be done by the examinee and the same should be addressed to the Court,
which alone can validly act thereon. Once the bar examiner has submitted the corrected
notebooks to the bar con dant the same cannot be withdrawn for any purpose whatsoever
without prior authority from the Court.
7. ID.; ADMISSION; REQUIREMENT; GOOD MORAL CHARACTER. — Section 2 of Rule
138 of the Revised Rules of Court of 1964, among others, provides that "every applicant for
admission as a member of the Bar must . . . of good moral character . . . and must produce
before the Supreme Court satisfactory evidence of good moral character, and that no charges
against him involving moral turpitude have been led or are pending in any court in the
Philippines." Prior to 1964, or under the old Rules of Court, a bar applicants was required to
produce before the Supreme Court satisfactory testimonials of good moral character (Sec. 2,
Rule 127). Under both rules, every applicant is duty bound to lay before the Court all his
involvement in any criminal case, pending or otherwise terminated, to enable the Court to fully
ascertain or determine applicant's moral character. Furthermore, as to what crime involves
moral turpitude is for the Supreme Court to determine. Hence, the necessity of laying before
or informing the Court of one's personal record, whether he was criminally indicted, acquitted,
convicted or the case dismissed or is still pending becomes more compelling.
8. ID.; ID.; ID.; CASE AT BAR. — An applicant's intentional withholding or
concealment from the Supreme Court of his pending case of slight physical injuries of his
application to take the bar examination of 1962, 1963, 1964, 1966, 1967, 1969 and 1971, by
virtue of which he was allowed unconditionally to take the examinations seven times and to
take his oath in 1972, is a ground for disbarment.
9. ID.; EXAMINERS REQUIRED TO EXERCISE UTMOST CARE. — Examiner's
participation in the admission of members to the Bar is one impressed with the highest
consideration of public interest — absolute purity of the proceedings — and so are required to
exercise the greatest or utmost care and vigilance in the performance of their duties relative
thereto.
10. ATTORNEYS; REVOCATION OF LICENSE. — Well-settled is the rule that
concealment by an attorney in his application to take the Bar Examinations of the fact that he
had been charged with, or indicated for, a crime, is a ground for revocation of his license to
practice law.
11. ANTI-GRAFT LAW; DISMISSAL OF PUBLIC OFFICER UNDER SECTION 8,
REPUBLIC ACT NO. 3019. Section 8 of Republic Act No. 3019 authorized the dismissal on
removal of a public o cer once it is determined that his property or money "is manifestly out
of proportion to his salary as such public o cer or employee and to his other lawful income
and the income from legitimately acquired property . . . "
DECISION
MAKASIAR, J : p
Administrative proceedings against Victorio D. Lanuevo — for disbarment; Ramon E.

Galang, alias Roman E. Galang — for disbarment; Hon. Bernardo Pardo, Hon. Ramon Pamatian,
Atty. Manuel C. Tomacruz; Atty. Manuel G. Montecillo, Atty. Fidel Manalo and Atty. Guillermo
Pablo, Jr. — for disciplinary action — for their acts and omissions during the 1971 Bar
Examinations.
In his request dated March 29, 1972 contained in a con dential letter to the Court for
re-correction and re-evaluation of his answers to the 1971 Bar Examinations questions, Oscar
Landicho — who unked in the 1971, 1968 and 1967 Bar Examinations with a grade of 70.5%,
65.35% and 67.55%, respectively — invited the attention of the Court to "The starting fact that
the grade in one examination (Civil Law) of at least one bar candidate was raised for one
reason or another, before the bar results were released this year" (Confidential Letter, p. 2. Vol.
I, rec.). This was con rmed, according to him, by the Civil Law Examiner himself (Hon. Ramon
C. Pamatian) as well as by Bar Con dant Victorio D. Lanuevo. He further therein stated "that
there are strong reasons to believe that the grades in other examination notebooks in other
subjects also underwent alterations — to raise the grades — prior to the release of the results.
Note that this was without any formal motion or requests from the proper parties, i.e., the bar
candidates concerned. If the bar examiners concerned reconsidered their grades without
formal motion, there is no reason why they may not do so now when proper request and
motion therefor is made. It would be contrary to due process postulates. Might not one say
that some candidates got unfair and unjust treatment, for their grades were not asked to be
reconsidered 'uno cially'? Why the discrimination? Does this not afford su cient reason for
the Court en banc to go into these matters by its conceded power to ultimately decide the
matter of admission to the bar?" (p. 2, Confidential Letter, Vol. I, rec.).
Acting on the aforesaid con dential letter, the Court checked the records of the 1971
Bar Examinations and found that the grades in ve subjects — Political Law and Public
International Law, Civil Law, Mercantile Law, Criminal Law and Remedial Law — of a successful
bar candidate with o ce code No. 954 underwent some changes which, however, were duly
initialed and authenticated by the respective examiner concerned. Further check of the
records revealed that the bar candidate with o ce code No. 954 is one Ramon E. Galang,
alias Roman E. Galang, a perennial bar candidate, who unked in the 1969, 1967, 1966, 1964,
1963, and 1962 bar examinations with a grade of 67.55%, 68.65%, 72.75%, 68.2%, 56.45% and
57.3%, respectively. He passed in the 1971 bar examinations with a grade of 74.15%, which
was considered as 75% by virtue of a Court resolution making 74% as the passing mark for
the 1971 bar examinations.
Upon the direction of the Court, the 1971 Bar Examination Chairman requested Bar
Con dant Victorio D. Lanuevo and the ve (5) bar examiners concerned to submit their sworn
statements on the matter, with which request they complied.
In his sworn statement dated April 12, 1972, said Bar Con dant admitted having
brought the ve examination notebooks of Ramon E. Galang, alias Roman E. Galang, back to
the respective examiners for re-evaluation and/or re-checking, stating the circumstances
under which the same was done and his reasons for doing the same.
Each of the ve (5) examiners in his individual sworn statement admitted having re-
evaluated and/or re-checked the notebook involved pertaining to his subject upon the
representation to him by Bar Con dant Lanuevo that he has the authority to do the same and
that the examinee concerned failed only in his particular subject and/or was on the borderline
of passing.
Finding a prima facie case against the respondents warranting a formal investigation,
the Court required, in a resolution dated March 5,1973, Bar Con dant Victorio Lanuevo "to
show cause within ten (10) days from notice why his name should not be stricken from the
Roll of Attorneys" (Adm. Case No. 1162, p. 34, rec.). Considering that the re-evaluation of the
examination papers of Ramon E. Galang, alias Roman E. Galang, was unauthorized, and
therefore he did not obtain a passing average in the 1971 bar examinations, the Court likewise
resolved on March 5, 1971 to require him "to show cause within ten (10) days from notice why
his name should not be stricken from the Roll of Attorneys" (Adm. Case No. 1163, p. 99, rec.).
The ve examiners concerned were also required by the Court "to show cause within ten (10)
days from notice why no disciplinary action should be taken against them" (Adm. Case No.
1164, p. 31, rec.).
Respondent Tomacruz led his answer on March 12, 1973 (Adm. Case No. 1164, p. 70,
rec.) while respondents Pardo, Pamatian, Montecillo, Manalo and Lanuevo led theirs on
March 19,1973 (Adm. Case No. 1162, pp. 60-63, 32-35, 40-41, 36-39 and 35-38, rec.). At the
hearing on August 27, 1973, respondent Lanuevo led another sworn statement in addition to,
and in ampli cation of, his answer led on March 19, 1973 (Adm. Case No. 1162, pp. 45-47,
rec.). Respondent Galang led his unveri ed answer on March 16, 1973 (Adm. Case No. 1163,
pp. 100-104, rec.). He was required by the Court to verify the same and compliance came on
May 18, 1973 (Adm. Case No. 1163, pp. 106-110, rec.).
In the course of the investigation, it was found that it was not respondent Bernardo
Pardo who re-evaluated and/or rechecked examination booklet with O ce Code No. 954 in
Political Law and Public International Law of examinee Ramon Galang, alias Roman E. Galang,
but Guillermo Pablo, Jr., examiner in Legal Ethics and Practical Exercises, who was asked to
help in the correction of a number of examination notebooks in Political Law and Public
International Law to meet the deadline for submission (pp. 17-24, Vol. V, rec.). Because of this
development, Atty. Guillermo Pablo, Jr. was likewise included as respondent in Administrative
Case No. 1164. Hon. Bernardo Pardo remained as a respondent for it was also discovered
that another paper in Political Law and Public International Law also underwent re-evaluation
and/or re-checking. This notebook with O ce Code No. 1622 turned out to be owned by
another successful candidate by the name of Ernesto Quitaleg . Further investigation resulted
in the discovery of another re-evaluation and/or re-checking of a notebook in the subject of
Mercantile Law resulting in the change of the grade from 47% to 50%. This notebook bearing
Office Code No. 110 is owned by another successful candidate by the name of Alfredo Ty dela
Cruz. Quitaleg and Ty dela Cruz and the latter's father were summoned to testify in the
investigation.
An investigation conducted by the National Bureau of Investigation upon request of the
Chairman of the 1971 Bar Examination Committee as Investigating O cer, showed that one
Romy Galang y Esguerra, alias Ramon E. Galang, a student in the School of Law of Manuel L.
Quezon University, was, on September 8, 1959, charged with the crime of slight physical
injuries in the Municipal Court of Manila committed on Eufrosino F. de Vera, another student
of the same university. Confronted with this information at the hearing of August 13, 1973
(Vol. V, pp. 20-21, 32, rec.), respondent Galang declared that he does not remember having
been charged with the crime of slight physical injuries. Because of this denial, a summons was
issued to Eufrosino F. de Vera, who narrated the circumstances surrounding the case and
identi ed respondent Galang as the very same person charged with the crime of slight
physical injuries in that case (Vol. VI, pp. 45-60, rec.).
Respondent Galang, in all his applications to take the bar examinations, did not make
mention of this fact which he is required under the rules to do.
The joint investigation of all the cases commenced on July 17, 1973 and was
terminated on October 2, 1973. Thereafter, parties-respondents were required to submit their
memoranda. Respondents Lanuevo, Galang and Pardo submitted their respective
memorandum on November 14, 1973.
Before the joint hearing commenced, Oscar Landicho took up permanent residence in
Australia, where he is believed to be gainfully employed. Hence, he was not summoned to
testify.
At the joint investigation, all respondents, except respondent Pablo, who offered as
evidence only his oral testimony, submitted as their direct evidence the a davits and answers
earlier submitted by them to the Court. The same became the basis for their cross-
examination.
In their individual sworn statements and answers, which they offered as their direct
testimony in the investigation conducted by the Court, the respondents-examiners recounted
the circumstances under which they re-evaluated and/or re-checked the examination
notebooks in question.
In His a davit dated April 11, 1972, respondent Judge (later Associate Justice of the
Court of Appeals) Ramon C. Pamatian, examiner in Civil Law, affirmed:
"2. That one evening sometime in December last year, while I was correcting
the examination notebooks, Atty. Lanuevo, Bar Con dant, explained to me that it is the
practice and the policy in bar examinations that he (Atty. Lanuevo) make a review of the
grades obtained in all segments and if he nds that candidate obtained an
extraordinarily high grade in one subject and a rather low one in another, he will bring
back the latter to the examiner concerned for re-evaluation and change of grade;
"3. That sometime in the latter part of January of this year, he brought back to
me an examination booklet in Civil Law for re-evaluation, because according to him the
owner of the paper is on the borderline and if I could reconsider this grade to 75% the
candidate concerned will get passing mark;
"4. That taking his word for it and under the belief that it was really the
practice and policy of the Supreme Court to do so in the further belief that I was just
manifesting cooperation indoing so, I re-evaluated the paper and reconsidered the grade
to 75%;
"5. That only one notebook in Civil Law was brought back to me for such re-
evaluation and upon verifying my files I found that the notebook is number '95';
"6. That the original grade was 64% and my re-evaluation of the answers were
based on the same standard used in the correction and evaluation of all others; thus,
Nos. 3 and 4 with original grades of 7% each was reconsidered to 10%; No. 5 with 4% to
5%; No. 7 with 3% to 5%; and No. 8 with 8% to 10%" (underscoring supplied).
His answer dated March 19, 1973 substantially reiterated his allegations in his
April 11, 1972 affidavit with the following additional statements:
xxx xxx xxx
"3. . . . . However the grades in Nos. 1, 2, 6, 9 and 10, were not reconsidered as
it is no longer possible to make the reconsideration of these answers because of the
same evaluation and standard; hence, Nos. 1, 2 and 10 remained at 5% and Nos. 6 and 9
at 10%;
"4. That at the time I made the reconsideration of examination booklet No. 95
I did not know the identity of its owner until I received this resolution of the Honorable
Supreme Court nor the identities of the examiners in other subjects;
"5. That the above re-evaluation was made in good faith and under the belief
that I am authorized to do so in view of the misrepresentation of said Atty. Lanuevo,
based on the following circumstances:
"a) Since I started correcting the papers on or about October 16,
1971, relationship between Atty. Lanuevo and myself had developed to the
point that with respect to the correction of the examination booklets of bar
candidates I have always followed him and considered his instructions as
re ecting the rules and policy of the Honorable Supreme Court with respect to
the same; that I have no alternative but to take his words;
"b) That considering this relationship and considering his
misrepresentation to me as re ecting the real rules and policy of the
Honorable Supreme Court, I did not bother any more to get the consent and
permission of the Chairman of the Bar Committee. Besides, at that time, I was
isolating myself from all members of the Supreme Court and specially the
chairman of the Bar Committee for fear that I might he identi ed as a bar
examiner;
xxx xxx xxx

"e) That no consideration whatsoever has been received by me in
return for such recorrection, and as proof of it, I declined to reconsider and
evaluate one booklet in Remedial Law aforesaid because I was not the one
who made the original correction of the same" (Adm. Case No. 1164, pp. 32-
35, rec.; emphasis supplied).
Then Assistant Solicitor General, now CFI Judge, Bernardo Pardo, examiner in Political
Law and Public International Law, confirmed in his affidavit of April 8, 1972 that:
"On a day or two after the Bar Con dant went to my residence to obtain from me
the last bag of two hundred notebooks (bearing examiner's code numbers 1200 to 1400)
which according to my record was on February 5, 1972, he came to my residence at
about 7:30 p.m. riding in a Vokswagen panel of the Supreme Court, with at least two
companions. The bar con dant had with him an examinee's notebook bearing code
number 661, and, after the usual amenities, he requested me if it was possible for me to
review and re-examine the said notebook because it appears that the examinee obtained
a grade of 57, whereas, according to the Bar Con dant, the said examinee had obtained
higher grades in other subjects, the highest of which was 84, if I recall correctly, in
remedial law.
"I asked the Bar Con dant if I was allowed to review or re-examine the notebook
as I had submitted the same beforehand, and he told me that I was authorized to do so
because the same was still within my control and authority as long as the particular
examinee's name had not been identi ed or that the code number decoded and the
examinee's name was revealed. The Bar Con dant told me that the name of the
examinee in the case presented hearing code number 661 had not been identi ed or
revealed; and that it might have been possible that I had given a particularly low grade to
said examinee.
"Accepting at face value the truth of the Bar Con dant's representations to me,
and as it was humanly possible that I might have erred in the grading of the said
notebook, I re-examined the same, carefully read the answers, and graded it in
accordance with the same standards I had used throughout the grading of the entire
notebooks, with the result that the examinee deserved an increased grade of 66. After
again clearing with the Bar Con dant my authority to correct the grades and as he had
assured me that the code number of the examinee in question had not been decoded
and his name known, . . . I therefore corrected the total grade in the notebook and the
grade card attached thereto, and properly initia(l)ed the same. I also corrected the
itemized grades (from item No. 1 to item No. 10) on the two sets of grading sheets, my
personal copy thereof, and the Bar Con dant brought with him the other copy of the
grading sheet" (Adm. Case No. 1164, pp. 58-59; rec.; emphasis supplied).
In his answer dated March 17, 1973 which he denominated as "Explanation",

respondent Bernardo P. Pardo adopted and repleaded therein by reference the facts stated in
his earlier sworn statement and in addition alleged that:
xxx xxx xxx
"3.At the time I reviewed the examinee's notebook in political and international
law, code numbered 661, I did not know the name of the examinee. In fact, I came to
know his name only upon receipt of the resolution of March 5, 1973; now knowing his
name, I wish to state that I do not know him personally, and that I have never met him
even up to the present;
"4.At that time, I acted under the impression that I was authorized to make such
review and had repeatedly asked the Bar Con dant whether I was authorized to make
such revision and was so assured of my authority as the name of the examinee had not
yet been decoded or his identity revealed, the Bar Con dant's assurance was apparently
regular and so appeared to be in the regular course of o cial business which thus
convinced me because there was no express prohibition in the rules and guidelines given
to me as an examiner, and the Bar Con dant was my o cial liaison with the Chairman,
as, unless called, I refrained as much as possible from frequent personal contact with
the Chairman lest I be identified as an examiner. . . .;
"5.At the time the Bar Con dant came to see me at about 7:30 o'clock in the
evening at my residence, I felt it inappropriate to verify his authority with the Chairman. It
did not appear to me that his representation were unauthorized or suspicious. Indeed, the
Bar Con dant was riding in the o cial vehicle of the Supreme Court, a Volkswagen
panel, accompanied by two companions, which was usual, and thus looked like a regular
visit to me of the Bar Confidant, as it was about the same hour that he used to see me:
xxx xxx xxx
"7.Indeed, the notebook code numbered 661 was still in the same condition as
when I submitted the same. In agreeing to review the said notebook code numbered 661,
my aim was to see if I committed an error in the correction, not to make the examinee
pass the subject. I considered it entirely humanly possible to have erred because I
corrected that particular notebook on December 31, 1971, considering especially the
representation of the Bar Con dant that the said examinee had obtained higher grades
in other subjects, the highest of which was 84% in remedial law, if I recall correctly. Of
course, it did not strike me as unusual that the Bar Con dant knew the grades of the
examinee in the other subjects; I presumed that, as Bar Con dant, he was in the position
to know and that there was nothing irregular in that:
"8.In political and international law, the original grade obtained by the examinee
with notebook code numbered 661 was 57%. After review, it was increased by 9 points,
resulting in a nal grade of 661. Still, the examinee did not pass the subject, and, as
heretofore stated, my aim was not to make the examinee pass, notwithstanding the
representation that he had passed the other subjects. . . .
"9.I quite recall that during the rst meeting of the Bar Examiners' Committee,
which according to my diary was on February 8, 1972, the committee consensus was
that where an examinee failed in only one subject and passed the rest, the examiner in
said subject would review the notebook. Nobody objected to it as irregular. At the time of
the Committee's first meeting, we still did not know the names of the candidates.
"10.In ne, I was a victim of deception, not a party to it . I had absolutely no
knowledge of the motives of the Bar Con dant or his malfeasance in o ce, and did not
know the examinee concerned nor had I any kind of contact with him before or after the
review and even up to the present" (Adm. Case No. 1164, pp. 60-63; rec.; emphasis
supplied).
Atty. Manuel Tomacruz, examiner in Criminal Law, a rmed in his a davit dated April
12, 1972:
"1. . . .
"2. That about weekly, the Bar Con dant would deliver and collect
examination books to my then residence at 951 Luna Mencias, Mandaluyong, Rizal.
"3. That towards the end when I had already completed correction of the
books in Criminal Law and was helping in the correction of some of the papers in
another subject, the Bar Con dant brought back to me one (1) paper in Criminal Law
saving that particular examinee had missed the passing grade by only a fraction of a
percent and that if his paper in Criminal Law would be raised a few points to 75% then
he would make the general passing average.
"4. That seeing the justi cation, I raised the grade to 75%, that is, giving a
raise of, if I remember correctly, 2 or 3 points, initialled the revised mark and revised also
the mark in the general list.
"5. That I do not recall the number of the book of the examinee concerned"
(Adm. Case No. 1164, p. 69, rec.; emphasis supplied).
In his answer dated March 12, 1973, respondent Tomacruz stated that " I accepted the
word of the Bar Con dant in good faith and without the slightest inkling as to the identity of
the examinee in question who up to now remains a total stranger and without expectation of
nor did I derive any personal benefit" (Adm. Case No. 1164, p. 70, rec.; emphasis supplied).
Atty. Fidel Manalo, examiner in Remedial Law, stated in his a davit dated April 14,
1972, that:
xxx xxx xxx
"2. Sometime about the late part of January or early part of February 1912,
Attorney Lanuevo, Bar Con dant of the Supreme Court, saw me in my house at No. 1854
Asuncion Street, Makati, Rizal. He produced to me an examinee's notebook in Remedial
Law which I had previously graded and submitted to him. He informed me that he and
others (he used the word 'we') had reviewed the said notebook. He requested me to
review the said notebook and possibly reconsider the grade that I had previously given.
He explained that the examinee concerned had done well in other subjects, but that
because of the comparatively low grade that I had given him in Remedial Law his
general average was short of passing. Mr. Lanuevo remarked that he thought that if the
paper were reviewed I might find the examinee deserving of being admitted to the Bar. As
far as I can recall, Mr. Lanuevo particularly called my attention to the fact in his answers
the examinee expressed himself clearly and in good enough English. Mr. Lanuevo
however informed me that whether I would reconsider the grades I had previously given
and submitted was entirely within my discretion.
"3. Believing fully that it was within Mr. Lanuevo's authority as Bar Con dant
to address such a request to me and that the said request was in order, I, in the presence
of Mr. Lanuevo, proceeded to re-read and re-evaluate each and every item of the paper in
question. I recall that in my re-evaluation of the answers, I increased the grades in some
items, made deductions in other items, and maintained the same grades in other items.
However, I recall that after Mr. Lanuevo and I had totalled the new grades that I had
given after re-evaluation, the total grade increased by a few points, but still short of the
passing mark of 75% in my subject.
. . ." (Adm. Case No. 1164, pp. 74-75, rec.; emphasis supplied).
In his answer (response) dated March 18, 1973, respondent Manalo reiterated the
contents of his sworn statement, adding the following:
xxx xxx xxx
"5. In agreeing to re-evaluate the notebook, with resulted in increasing the
total grade of the examinee concerned in Remedial Law from 63.75% to 74.5%, herein
respondent acted in good faith. It may well be that he could be faulted for not having
veri ed from the Chairman of the Committee of Bar Examiners the legitimacy of the
request made by Mr. Lanuevo. Herein respondent, however, pleads in attenuation of such
omission, that —
"a) Having been appointed an Examiner for the rst time, he was
not aware, not having been apprised otherwise, that it was not within the
authority of the Bar Con dant of the Supreme Court to request or suggest that
the grade of a particular examination notebook be revised or reconsidered. He
had every right to presume, owing to the highly duciary nature of the position
of the Bar Confidant, that the request was legitimate.
xxx xxx xxx
"c) In revising the grade of the particular examinee concerned,
herein respondent carefully evaluated each and every answer written in the
notebook. Testing the answers by the criteria laid down by the Court, and
giving the said examinee the bene t of doubt in view of Mr. Lanuevo's
representation that it was only in that particular subject that the said examinee
failed, herein respondent became convinced that the said examinee deserved
a higher grade than that previously given to him, but that he did not deserve, in
herein respondent's honest appraisal, to be given the passing grade of 75%. It
should also be mentioned that, in reappraising the answers, herein respondent
downgraded a previous rating of an answer written by the examinee, from
9.25% to 9%" (Adm. Case No. 1164, pp. 36-39, rec.; emphasis supplied).
Atty. Manuel Montecillo, examiner in Mercantile Law, a rmed in his a davit dated April
17, 1972:
xxx xxx xxx
"That during one of the deliberations of the Bar Examiners' Committee after the
Bar Examinations were held, I was informed the one Bar examinee passed all other
subjects except Mercantile Law;
"That I informed the Bar Examiners' Committee that I would be willing to re-
evaluate the paper of this particular Bar candidate;
"That the next day, the Bar Con dant handed to me a Bar candidate's notebook
(No. 1613) showing a grade of 61%;
"That I reviewed the who]e paper and after re-evaluating the answers of this
particular Bar candidate I decided to increase his final grade to 71%;
"That consequently, I amended my report and duly initialed the changes in the
grade sheet" (Adm. Case No. 1164, p. 72, rec.; italics supplied).
In his answer dated March 19, 1973, respondent Montecillo restated the contents of his
sworn statement of April 17, 1972, and
xxx xxx xxx
"2.Supplementary to the foregoing sworn statement, I hereby state that I re-
evaluated the examination notebook of Bar Candidate No. 1613 in Mercantile Law in
absolute good faith and in direct compliance with the agreement made during one of the
deliberations of the Bar Examiners Committee that where a candidate fails in only one
subject, the Examiner concerned should make a re-evaluation of the answers of the
candidate concerned, which I did.
"3.Finally, I hereby state that I did not know at the time I made the aforementioned
re-evaluation that notebook No. 1613 in Mercantile Law pertained to bar examinee
Ramon E. Galang, alias Roman E. Galang, and that I have never met up to this time this
particular bar examinee" (Adm. Case No. 1164, pp. 40-41, rec.; emphasis supplied).
In his sworn statement dated April 12, 1972, Bar Confidant Lanuevo stated:
xxx xxx xxx
"As I was going over those notebooks, checking the entries in the grading sheets
and the posting on the record of ratings, I was impressed of the writing and the answers
on the rst notebook. This led me to scrutinize all the set of notebooks. Believing that
those ve merited re-evaluation on the basis of the memorandum circularized to the
examiners shortly earlier to the effect that.
. . . in the correction of the papers, substantial weight should then be
given to clarity of language and soundness of reasoning (par. 4),
I took it upon myself to bring them back to the respective examiners for re-
evaluation and/or re-checking.
"It is our experience in the Bar Division that immediately after the release of the
results of the examinations, we are usually swarmed with requests of the examinees that
they be shown their notebooks. Many of them would copy their answers and have them
checked by their professors. Eventually some of them would le motions or requests for
re-correction and/or re-evaluation. Right now, we have some 19 of such motions or
requests which we are readying for submission to the Honorable Court.
"Often we feel that a few of them are meritorious, but just the same they have to
be denied because the result of the examinations when released is final and irrevocable.
"It was to at least minimize the occurrence of such instances that motivated me to
bring those notebooks back to the respective examiners for re-evaluation" (Adm. Case
No. 1162, p. 24, rec.; italics supplied).

In his answer dated March 19, 1973, respondent Lanuevo avers:
"That he submitted the notebooks in question to the examiners concerned in his
honest belief that the same merited re-evaluation; that in so doing, it was not his
intention to forsake or betray the trust reposed in him as bar con dant but on the
contrary to do justice to the examinee concerned; that neither did he act in a
presumptuous manner, because the matter of whether or not re-evaluation was in order
was left alone to the examiners' decision; and that, to his knowledge, he does not
remember having made the alleged misrepresentation but that he remembers having
brought to the attention of the Committee during the meeting a matter concerning
another examinee who obtained a passing general average but with a grade below 50%
in Mercantile Law. As the Committee agreed to remove the disquali cation by way of
raising the grade in said subject, respondent brought the notebook in question to the
Examiner concerned who thereby raised the grade thus enabling the said examinee to
pass. If he remembers right, the examinee concerned is one surnamed 'de la Cruz' or 'Ty-
de la Cruz'.
"Your Honors, respondent never entertained a notion that his act would stir such
serious charges as would tend to undermine his integrity because he did it in all good
faith.
". . ." (Adm. Case No. 1162, p. 35, rec.; emphasis supplied).
On August 27, 1973, during the course of the investigation, respondent Lanuevo led
another sworn statement in addition to, and in amplification of, his answer, stating:
xxx xxx xxx
"1. That I vehemently deny having deceived the examiners concerned into
believing that the examinee involved failed only in their respective subjects, the fact of
the matter being that the notebooks in question were submitted to the respective
examiners for re-evaluation believing in all good faith that they so merited on the basis
of the Con dential Memorandum (identi ed and marked as Exh. 1-Lanuevo, particularly
that portion marked as Exh. 1-a-Lanuevo) which was circulated to all the examiners
earlier, leaving to them entirely the matter of whether or not re-evaluation was in order;
"2. That the following coincidence prompted me to pry into the notebooks in
question:
"Sometime during the latter part of January and the early part of
February, 1972, on my way hack to the o ce (Bar Division) after lunch, I
thought of buying a sweepstake ticket. I have always made it a point that the
moment I think of so buying, I pick a number from any object and the rst
number that comes into my sight becomes the basis of the ticket that I buy. At
that moment, the rst number that I saw was '954' boldly printed on an
electrical contribance (evidently belonging to the MERALCO) attached to a
post standing along the right sidewalk of P. Faura street towards the Supreme
Court building from San Marcelino street and almost adjacent to the
southeastern corner of the fence of the Araullo High School (photograph of
the number '954', the contrivance on which it is printed and a portion of the
post to which it is attached is identi ed and marked as Exhibit 4-Lanuevo and
the number '954' as Exh. 4-a-Lanuevo).
"With this number (954) in mind, I proceeded to Plaza Sta. Cruz to look
for a ticket that would contain such number. Eventually, I found a ticket, which
I then bought, whose last three digits corresponded to '954'. This number
became doubly impressive to me because the sum of all the six digits of the
ticket number was '27', a number that is so signi cant to me that everything I
do I try somewhat instinctively to link or connect it with said number whenever
possible. Thus even in assigning code numbers on the Master List of
examinees from 1968 when I rst took charge of the examinations as bar
con dant up to 1971, I either started with the number '27' (or '227') or end with
said number. (1968 Master List is identi ed and marked as Exh. 5-Lanuevo
and the gure '27' at the beginning of the list, as Exh. 5-a-Lanuevo; 1969
Master List as Exh. 6-Lanuevo and the gure '227' at the beginning of the list,
as Exh. 6-a-Lanuevo; 1970 Master List as Exh. 7-Lanuevo and the gure '227'
at the beginning of the list as Exh. 7-a-Lanuevo; and the 1971 Master List as
Exh. 8-Lanuevo and the figure '227' at the end of the list as Exh. 8-a-Lanuevo).
"The signi cance to me of this number (27) was born out of these
incidents in my life, to wit: (a) On November 27, 1941 while with the Philippine
Army stationed at Camp Manacnac, Cabanatuan, Nueva Ecija, I was stricken
with pneumonia and was hospitalized at the Nueva Ecija Provincial Hospital
as a result. As will be recalled, the last Paci c War broke out on December 8,
1941. While I was still con ned at the hospital, our camp was bombed and
strafed by Japanese planes on December 13, 1941 resulting in many
casualties. From then on, I regarded November 27, 1941 as the beginning of a
new life for me having been saved from the possibility of being among the
casualties; (b) On February 27, 1946, I was able to get out of the army by way
of honorable discharge; and (c) on February 27, 1947, I got married and since
then we begot children the youngest of whom was born on February 27, 1957.
"Returning to the o ce that same afternoon after buying the ticket, I
resumed my work which at the time was on the checking of the notebooks.
While thus checking, I came upon the notebooks bearing the o ce code
number '954'. As the number was still fresh in my mind, it aroused my
curiosity prompting me to pry into the contents of the notebooks. Impressed
by the clarity of the writing and language and the apparent soundness of the
answers and, thereby, believing in all good faith on the basis of the
aforementioned Con dential Memorandum (Exh. 1-Lanuevo and Exh. 1-a-
Lanuevo) that they merited re-evaluation, I set them aside and later on took
them back to the respective examiners for possible review recalling to them
the said Con dential Memorandum but leaving absolutely the matter to their
discretion and judgment.
"3. That the alleged misrepresentation or deception could have reference to
either of the two cases which I brought to the attention of the Committee during the
meeting and which the Committee agreed to refer back to the respective examiners,
namely:
"(a) That of an examinee who obtained a passing general average
but with a grade below 50% (47%) in Mercantile Law (the notebooks of this
examinee hear the O ce Code No. 110, identi ed and marked as Exh. 9-
Lanuevo and the notebook in Mercantile Law bearing the Examiner's Code No.
951 with the original grade of 47% increased to 50% after re-evaluation as Exh.
9-a-Lanuevo); and
"(b) That of an examinee who obtained a borderline general
average of 73.15% with a grade below 60% (57%) in one subject which, at the
time, I could not pinpoint having inadvertently left in the o ce the data
thereon. It turned out that the subject was Political and International Law
under Asst. Solicitor General Bernardo Pardo (The notebooks of this examinee
bear the O ce Code No. 1622 identi ed and marked as Exh. 10-Lanuevo and
the notebook in Political and International Law bearing the Examiner's Code
No. 661 with the original grade of 57% increased to 66% after re-evaluation, as
Exh. 10-a-Lanuevo). This notebook in Political and International Law is
precisely the same notebook mentioned in the sworn statement of Asst.
Solicitor General Bernardo Pardo (Exh. ----- Pardo).
"4. That in each of the two cases mentioned in the next preceding paragraph,
only one (1) subject or notebook was reviewed or re-evaluated, that is, only Mercantile
Law in the former; and only Political and International Law in the latter, under the facts
and circumstances I made known to the Committee and pursuant to which the
Committee authorized the referral of the notebooks involved to the examiners concerned;
"5. That at that juncture, the examiner in Taxation even volunteered to review
or re-check some 19, or so, notebooks in his subject but that I told the Committee that
there was very little time left and that the increase in grade after re-evaluation, unless
very highly substantial, may not alter the outcome since the subject carries the weight of
only 10%" (Adm. Case No. 1162, pp. 45-47, rec.).
The foregoing last-minute embellishment only serves to accentuate the fact that
Lanuevo's story is devoid of truth. In his sworn statement of April 12, 1972, he was "led
to scrutinize all the set of notebooks" of respondent Galang, because he "was impressed
of the writing and the answers on the rst notebook" as he "was going over those
notebooks, checking the entries in the grading sheets and the posting on the record of
ratings." In his a davit of August 27, 1973, he stated that the number 954 on a Meralco
post provoked him "to pry into the contents of the notebooks" of respondent Galang
"bearing office code number '954."
Respondent Ramon E. Galang, alias Roman E. Galang, asserted, among others;

"1. That herein respondent is not acquainted with former Bar Con dant
Victorio Lanuevo and never met him before except once when, as required by the latter
respondent submitted certain papers necessary for taking the bar examinations.
xxx xxx xxx
"4. That it has been the consistent policy of the Supreme Court not to
reconsider 'failure' cases; after the o cial release thereof; why should it now reconsider
a 'passing' case, especially in a situation where the respondent and the bar con dant do
not know each other and, indeed, met only once in the ordinary course of o cial
business?
"It is not inevitable, then, to conclude that the entire situation clearly manifests a
reasonable doubt to which respondent is richly entitled?
"5.That respondent, before reading a copy of this Honorable Court's resolution

dated March 5, 1973, had no knowledge whatsoever of former Bar Con dant Victorio
Lanuevo's actuations which are stated in particular in the resolution. In fact, the
respondent never knew this man intimately nor, had the herein respondent utilized
anyone to contact the Bar Confidant Lanuevo in his behalf.
"But, assuming as true, the said actuations of Bar Con dant Lanuevo as stated in
the Resolution, which are evidently purported to show as having redounded to the bene t
of herein respondent, these questions arise: First, was the re-evaluation of Respondent's
examination papers by the Bar Examination Committee done only or especially for him
and not done generally as regards the paper of the other bar candidates who are
supposed to have failed? If the re-evaluation of Respondent's grades was done among
those of others, then it must have been done as a matter of policy of the Committee to
increase the percentage of passing in that year's examination and, therefore, the
insinuation that only respondent's papers were re-evaluated upon the in uence of Bar
Con dant Lanuevo would be unjusti able, if not far fetched. Secondly, is the fact that
Bar Con dant Lanuevo's actuations resulted in herein Respondent's bene t an evidence
per se of Respondent's having caused actuations of Bar Con dant Lanuevo to be done
in former's behalf? To assume this could be disastrous in effect because that would be
presuming all the members of the Bar Examination Committee as devoid of integrity,
un t for the bar themselves and the result of their work that year, as also unworthy of
anything. All of these inferences are deductible from the narration of facts in the
resolution, and which only goes to show said narration of facts as unworthy of credence,
or consideration.
xxx xxx xxx

"7. This Honorable Tribunal's Resolution of March 5, 1973 would make this
Respondent Account or answer for the actuations of Bar Con dant Lanuevo as well as
for the actuations of the Bar Examiners implying the existence of some conspiracy
between them and the Respondent. The evident imputation is denied and it is contended
that the Bar Examiners were in the performance of their duties and that they should be
regarded as such in the consideration of this case.
". . ." (Adm. Case No. 1163, pp. 100-104, rec.).
I
The evidence thus disclosed clearly demonstrates how respondent Lanuevo
systematically and cleverly initiated and prepared the stage leading to the re-evaluation
and/or re-correction of the answers of respondent Galang by deceiving separately and
individually the respondents-examiners to make the desired revision without prior authority
from the Supreme Court after the corrected notebooks had been submitted to the Court
through the respondent Bar Con dant, who is simply the custodian thereof for and in behalf of
the Court.
It appears that one evening, sometime around the middle part of December, 1971 , just
before Christmas day, respondent Lanuevo approached Civil Law examiner Pamatian while the
latter was in the process of correcting examination booklets, and then and there made the
representations that as Bar Con dant, he makes a review of the grades obtained in all
subjects of the examinees and if he nds that a candidate obtains an extraordinarily high
grade in one subject and a rather low one in another, he will bring back to the examiner
concerned the notebook for re-evaluation and change of grade (Exh. 2-Pamatian, Adm. Case
No. 1164, pp. 55-56; Vol. V, pp. 34, rec.).
Sometime in the latter part of January, 1972 , respondent Lanuevo brought back to
respondent-examiner Pamatian an examination booklet in Civil Law for re-evaluation,
representing that the examinee who owned the particular notebook is on the borderline of
passing and if his grade in said subject could be reconsidered to 75%, the said examinee will
get a passing average. Respondent-examiner Pamatian took respondent Lanuevo's word and
under the belief that was really the practice and policy of the Supreme Court and in his further
belief that he was just manifesting cooperation in doing so, he re-evaluated the paper and
reconsidered the examinee's grade in said subject to 75% from 64%. The particular notebook
belonged to an examinee with Examiner's Code Number 95 and with Office Code Number 954.
This examinee is Ramon E. Galang, alias Roman E. Galang. Respondent Pamatian did not know
the identity of the examinee at the time he re-evaluated the said booklet (Exhs. 1-Pamatian, 2-
Pamatian, and 3-Pamatian, Adm. Case No. 1164, pp. 32-33, 55-56, 57; Vol. V, pp. 3-4, rec.).
Before Justice Pamatian made the revision, Examinee Galang failed in seven subjects
including Civil Law. After such revision, examinee Galang still failed in six subjects and could
not obtain the passing average of 75% for admission to the Bar.
Thereafter, about the latter part of January, 1972 or early part of February, 1972 ,
respondent Lanuevo went to the residence of respondent-examiner Fidel Manalo at 1854
Asuncion Street, Makati, Rizal, with an examinee's notebook in Remedial Law, which
respondent Manalo had previously corrected and graded. Respondent Lanuevo then
requested respondent Manalo to review the said notebook and possibly to reconsider the
grade given, explaining and representing that "they" had reviewed the said notebook and that
the examinee concerned had done well in other subjects, but that because of the
comparatively low grade given said examinee by respondent Manalo in Remedial Law, the
general average of said examinee was short of passing. Respondent Lanuevo likewise made
the remark and observation that he thought that if the notebook were reviewed, respondent
Manalo might yet nd the examinee deserving of being admitted to the Bar. Respondent
Lanuevo also particularly called the attention of respondent Manalo to the fact that in his
answers, the examinee expressed himself clearly and in good English. Furthermore,
respondent Lanuevo called the attention of respondent Manalo to Paragraph 4 of the
Confidential Memorandum that read as follows:
"4.Examination questions should be more a test of logic, knowledge of legal

fundamentals, and ability to analyze and solve legal problems rather than a test of
memory; in the correction of papers, substantial weight should be given to clarity of
language and soundness of reasoning."
Respondent Manalo was, however, informed by respondent Lanuevo that the matter of
reconsideration was entirely within his (Manalo's) discretion. Respondent Manalo, believing
that respondent Lanuevo, as Bar Con dant, had the authority to make such request and
further believing that such request was in order, proceeded to re-evaluate the examinee's
answers in the presence of Lanuevo, resulting in an increase of the examinee's grade in that
particular subject, Remedial Law, from 63.25% to 74.5%. Respondent Manalo authenticated
with his signature the changes made by him in the notebook and in the grading sheet. The said
notebook examiner's code number is 136, instead of 310 as earlier mentioned by him in his
a davit, and belonged to Ramon E. Galang, alias Roman E. Galang (Exhs. 1 & 2-Manalo, Adm.
Case No. 1164, pp. 36-39, 74-75; Vol. V, pp. 50-53, rec.).
But even after the re-evaluation by Atty. Manalo, examinee Galang could not make the
passing grade due to his failing marks in five subjects.
Likewise, in the latter part of January, 1972, on one occasion when respondent Lanuevo
went to deliver to respondent Guillermo Pablo, Jr. in the latter's house a new batch of
examination papers in Political Law and Public International Law to be corrected, respondent
Lanuevo brought out a notebook in Political Law bearing Examiner's Code Number 1752 (Exh.
5-Pardo, Adm. Case No. 1164, p. 66, rec.), informing respondent Pablo that particular
examinee who owns the said notebook seems to have passed in all other subjects except in
Political Law and Public International Law; and that if the said notebook would be re-evaluated
and the mark be increased to at least 75%, said examinee will pass the bar examinations. After
satisfying himself from respondent that this is possible — the respondent Bar Con dant
informing him that this is the practice of the Court to help out examinees who are failing in just
one subject — respondent Pablo acceded to the request and thereby told the Bar Con dant to
just leave the said notebook. Respondent Pablo thereafter re-evaluated the answers, this time
with leniency. After the re-evaluation, the grade was increased to 78% from 68%, or an
increase of 10%. Respondent Pablo then made the corresponding corrections in the grading
sheet and accordingly initialed the changes made. This notebook with O ce Code Number
954 also belonged to Ramon E. Galang, alias Roman E. Galang (Vol. V, pp. 43-46, rec.).
After the re-evaluation by Atty. Pablo, Jr., examinee Galang's general average was still
below the passing grade, because of his failing marks in four subjects.
Towards the end of the correction of examination notebooks, respondent Lanuevo
brought back to respondent Tomacruz one examination booklet in Criminal Law, with the
former informing the latter, who was then helping in the correction of papers in Political Law
and Public International Law, as he had already nished correcting the examination notebooks
in his assigned subject — Criminal Law — that the examinee who owns that particular
notebook had missed the passing grade by only a fraction of a percent and that if his grade in
Criminal Law would be raised a few points to 75%, then the examinee would make the passing
grade. Accepting the words of respondent Lanuevo, and seeing the justi cation and because
he did not want to be the one causing the failure of the examinee, respondent Tomacruz
raised the grade from 64% to 75% and thereafter, he initialed the revised mark and also
revised the mark in the general list and likewise initialed the same. The examinee's Examiner
Code Number is 746 while his O ce Code Number is 954. This examinee is Ramon E. Galang,
alias Roman E. Galang (Exhs. 1, 2 & 3-Tomacruz, Adm. Case No. 1164, pp. 65, 66 and 71; Vol.
V, pp. 24-25, 60-61, rec.).
Respondent Tomacruz does not recall having been shown any memo by respondent
Lanuevo when the latter approached him for this particular re-evaluation; but he remembers
Lanuevo declaring to him that where a candidate had almost made the passing average but
had failed in one subject, as a matter of policy of the Court, leniency is applied in reviewing the
examinee's notebook in the failing subject. He recalls, however, that he was provided a copy of
the Con dential Memorandum but this was long before the re-evaluation requested by
respondent Lanuevo as the same was received by him before the examination period (Vol. V,
p. 61, rec.).
However, such revision by Atty. Tomacruz could not raise Galang's general average to a
passing grade because of his failing mark in three more subjects, including Mercantile Law.
For the revision of examinee Galangs notebook in Mercantile Law, respondent Lanuevo neatly
set the last phase of his quite ingenious scheme — by securing authorization from the Bar
Examination Committee for the examiner in Mercantile Law to re-evaluate said notebook.
At the rst meeting of the Bar Examination Committee on February 8, 1972, respondent
Lanuevo suggested that where an examinee failed in only one subject and passed the rest, the
examiner concerned would review the notebook. Nobody objected to it as irregular and the
Committee adopted the suggestion (Exhs. A & B-Montecillo, Exh. 2-Pardo, Adm. Case No.
1161, pp. 41, 72, 63; Vol. Vi, p. 16, rec.).
At a subsequent meeting of the Bar Examination Committee, respondent Montecillo
was informed by respondent Lanuevo that a candidate passed all other subjects except
Mercantile Law. This information was made during the meeting within hearing of the other
members, who were all closely seated together. Respondent Montecillo made known his
willingness to re-evaluate the particular paper. The next day, respondent Lanuevo handed to
respondent Montecillo a bar candidate's notebook with Examiner's Code Number 1613 with a
grade of 61%. Respondent Montecillo then reviewed the whole paper and after re-evaluating
the answers, decided to increase the nal grade to 71% . The matter was not however
thereafter o cially brought to the Committee for consideration or decision (Exhs. A & B-
Montecillo, Adm. Case No. 1164, pp. 40-41, 70-11; Vol. V, pp. 33-34, rec.).
Respondent Montecillo declared that without being given the information that the
particular examinee failed only in his subject and passed all the others, he would not have
consented to make the re-evaluation of the said paper (Vol. V, p. 33, rec.). Respondent
Montecillo likewise added that there was only one instance he remembers, which is
substantiated by his personal records, that he had to change the grade of an examinee after
he had submitted his report, referring to the notebook of examinee Ramon E. Galang, alias
Roman E. Galang, with Examiner's Code Number 1613 and with O ce Code Number 954 (Vol.
V, pp 34-35, rec.).
A day or two after February 5, 1972, when respondent Lanuevo went to the residence of
respondent-examiner Pardo to obtain the last bag of 200 notebooks, respondent Lanuevo
returned to the residence of respondent Pardo riding in a Volkswagen panel of the Supreme
Court of the Philippines with two companions. According to respondent Lanuevo, this was
around the second week of February, 1972, after the rst meeting of the Bar Examination
Committee. Respondent Lanuevo had with him on that occasion an examinee's notebook
bearing Examiner's Code No. 661. Respondent Lanuevo, after the usual amenities, requested
respondent Pardo to review and re-examine, if possible, the said notebook because,
according to respondent Lanuevo, the examinee who owns that particular notebook obtained
higher grades in other subjects, the highest of which is 84% in Remedial Law. After clearing
with respondent Lanuevo his authority to reconsider the grades, respondent Pardo re-
evaluated the answers of the examinee concerned, resulting in an increase of grade from 57%
to 66%. Said notebook has number 1622 as o ce code number. It belonged to examinee
Ernesto Quitaleg (Exhs. 1 & 2-Pardo, Adm. Case No. 1164, pp. 58-63; Vol. V, pp. 12-24, 29-30,
rec.).
II
Re:Administrative Case No. 1162, Victorio D. Lanuevo, respondent.
A
UNAUTHORIZED RE-EVALUATION OF THE ANSWERS OF EXAMINEE RAMON E. GALANG, alias
ROMAN E. GALANG, alias IN ALL FIVE (5) MAJOR SUBJECTS.
Respondent Victorio D. Lanuevo admitted having requested on his own initiative the ve
examiners concerned to re-evaluate the ve notebooks of Ramon E. Galang, alias Roman E.
Galang, that eventually resulted in the increase of Galang's average from 66.25% to the
passing grade 74.15%, or a total increase of eight (8) weighted points, more or less, that
enabled Galang to hurdle the 1971 Bar examinations via a resolution of the Court making 74%
the passing average for that year's examination without any grade below fty percent (50%) in
any subject. Galang thereafter took his lawyer's oath. It is likewise beyond dispute that he had
no authority from the Court or the Committee to initiate such steps towards the said re-
evaluation of the answers of Galang or of other examinees.
Denying that he made representations to the examiners concerned that respondent
Galang failed only in their respective subjects and/or was on the borderline of passing,
respondent Lanuevo sought to justify his actuations on the authority of the aforequoted
paragraph 4 of the Con dential Memorandum (Exhs. 1 and 1-A-Lanuevo, Adm. Cases Nos.
1162 & 1164, p. 51, Adm. Case No. 1162; Vol. VII, p. 4, rec.) distributed to the members of the
Bar Examination Committee. He maintains that he acted in good faith and "in his honest belief
that the same merited re-evaluation; that in doing so, it was not his intention to forsake or
betray the trust reposed in him as Bar Con dant but on the contrary to do justice to the
examinee concerned; and that neither did he act in a presumptuous manner because the
matter of whether or not re-evaluation was in order was left alone to the examiners' decision . .
." (Exh. 2-Lanuevo, Adm. Case No. 1162, pp. 35-37, rec.).
But as openly admitted by him in the course of the investigation, the said con dential
memorandum was intended solely for the examiners to guide them in the initial correction of
the examination papers and never as a basis for him to even suggest to the examiners the re-
evaluation of the examination papers of the examinees (Vol. VII, p. 23, rec.). Any such
suggestion or request is not only presumptuous but also offensive to the norms of delicacy.
We believe the Examiners — Pablo, Manalo, Montecillo, Tomacruz, Pardo and Pamatian
— whose declarations on the matter of the misrepresentations and deceptions committed by
respondent Lanuevo, are clear and consistent as well as corroborate each other.
For indeed the facts unfolded by the declarations of the respondents-examiners (Adm.
Case No. 1164) and clari ed by extensive cross-examination conducted during the
investigation and hearing of the cases show how respondent Lanuevo adroitly maneuvered
the passing of examinee Ramon E. Galang, alias Roman E. Galang in the 1971 Bar
Examinations. It is patent likewise from the records that respondent Lanuevo took undue
advantage of the trust and con dence reposed in him by the Court and the Examiners implicit
in his position as Bar Con dant as well as the trust and con dence that prevailed in and
characterized his relationship with the ve members of the 1971 Bar Examination Committee,
who were thus deceived and induced into re-evaluating the answers of only respondent
Galang in ve subjects that resulted in the increase of his grades therein, ultimately enabling
him to be admitted a member of the Philippine Bar.
It was plain, simple and unmitigated deception that characterized respondent
Lanuevo's well-studied and well-calculated moves in successively representing separately to
each of the ve examiners concerned to the effect that the examinee failed only in his
particular subject and/or was on the borderline of passing. To repeat, before the unauthorized
re-evaluations were made, Galang failed in the ve (5) major subjects and in two (2) minor
subjects while his general average was only 66.25% — which under no circumstances or
standard could it be honestly claimed that the examinee failed only in one, or he was on the
borderline of passing. In fact, before the rst notebook of Galang was referred back to the
examiner concerned for re-evaluation, Galang had only one passing mark and this was in Legal
Ethics and Practical Exercises, a minor subject, with a grade of 81%. The averages and
individual grades of Galang before and after the unauthorized reevaluation are as follows:
B A I
1. Political Law and Public
International Law 68% 78% = 10 pts.
or 30 weighted points
B A I
Labor Laws and Social
Legislations 67% 67% = no re-
evaluation made.
2. Civil Law 64% 75% = 11 points
or 33 weighted points.
Taxation 74% 74% = no re-
evaluation made.
3. Mercantile Law 61% 71% = 10pts.
or 30 weighted points.
4. Criminal Law 64% 75% = 11 pts. or
22 weighted points.
5. Remedial Law 63.75% (64) 74.5% (75%) =
11 pts. or 44 weighted points.
Legal Ethics and Practical Exercises 81% 81% = no re
evaluation made.
———————————
General Weighted Averages 66.25% 74.15%
Hence, by the simple expedient of initiating the re-evaluation of the answers of Galang
in the ve (5) subjects under the circumstances already narrated, Galang's original average of
66.25% was increased to 74.15% or an increase of 7.9 weighted points, to the great damage
and prejudice of the integrity of the Bar examinations and to the disadvantage of the other
examinees. He did this in favor only of examinee Galang, with the possible addition of
examinees Ernesto Quitaleg and Alfredo Ty dela Cruz. But only one notebook was re-evaluated
for each of the latter two — Political Law and Public International Law for-Quitaleg and
Mercantile Law for Ty dela Cruz.
The O ce of the Bar Con dant, it must be stressed, has absolutely nothing to do in the
re-evaluation or reconsideration of the grades of examinees who fail to make the passing
mark before or after their notebooks are submitted to it by the Examiners. After the corrected
notebooks are submitted to him by the Examiners, his only function is to tally the individual
grades of every examinee in all subjects taken and thereafter compute the general average.
That done, he will then prepare a comparative data showing the percentage of passing and
failing in relation to a certain average to be submitted to the Committee and to the Court and
on the basis of which the Court will determine the passing average, whether 75 or 74 or 73,
etc. The Bar Con dant has no business evaluating the answers of the examinees and cannot
assume the functions of passing upon the appraisal made by the Examiner concerned. He is
not the over-all Examiner. He cannot presume to know better than the Examiner. Any request
for re-evaluation should be done by the examinee and the same should be addressed to the
Court, which alone can validly act thereon. A Bar Con dant who takes such initiative, exposes
himself to suspicion and thereby compromises his position as well as the image of the Court.
Respondent Lanuevo's claim that he was merely doing justice to Galang without any
intention of betraying the trust and con dence reposed in him by the Court as Bar Con dant,
can hardly invite belief in the face of the incontrovertible fact that he singled out Galang's
papers for re-evaluation, leaving out the papers of more than ninety (90) examinees with far
better averages ranging from 70% to 73 9% of which he was fully aware (Vol. VI, pp. 46-47,
101, rec.), which could be more properly claimed as borderline cases. This fact further betrays
respondent Lanuevo's claim of absolute good faith in referring back the papers of Galang to
the Examiners for re-evaluation. For certainly, as against the original weighted average of
66.25%, of Galang, there can hardly be any dispute that the cases of the aforesaid more than
ninety (90) examinees were more deserving of reconsideration. Hence, in trying to do justice
to Galang, as claimed by respondent Lanuevo, grave injustice was in icted on the other
examinees of the 1971 Bar examinations, especially the said more than ninety candidates.
And the unexplained failure of respondent Lanuevo to apprise the Court or the Committee or
even the Bar Chairman of the fact of re-evaluation before or after the said re-evaluation and
increase of grades, precludes, as the same is inconsistent with, any pretension of good faith.
His request for the re-evaluation of the notebook in Political Law and International Law
of Ernesto Quitaleg and the notebook in Mercantile Law of Alfredo Ty dela Cruz was to give
his actuations in the case of Galang a semblance of impartiality, hoping that the over ninety
examinees who were far better situated than Galang would not give him away. Even the
reevaluation of one notebook of Quitaleg and one notebook of Ty dela Cruz violated the
agreement of the members of the 1971 Bar Examination Committee to re-evaluate when the
examinee concerned fails only in one subject. Quitaleg and Ty dela Cruz failed in four (4) and
three (3) subjects respectively — as hereinafter shown.
The strange story concerning the gures 954, the o ce code number given to Galang's
notebook, unveiled for the rst time by respondent Lanuevo in his supplemental sworn
statement (Exh. 3-Lanuevo, Adm. Case No. 1162, pp. 45-47, rec.) led during the investigation
with this Court as to why he pried into the papers of Galang deserves scant consideration. It
only serves to picture a man desperately clutching at straws in the wind for support.
Furthermore, it was revealed by respondent Lanuevo for the rst time only on August 27, 1973
or a period of more than ve (5) months after he led his answer on March 19, 1973 (Exh. 2-
Lanuevo, Adm. Case No. 1162, pp. 35-36, rec.), showing that it was just an after-thought.
B
REFERRAL OF EXAMINEE ALFREDO TY DELA CRUZ' NOTEBOOK IN MERCANTILE LAW TO
RAISE HIS GRADE OF 47% TO 50% TO EXAMINER MANUEL MONTECILLO AND OF EXAMINEE
ERNESTO QUITALEG'S NOTEBOOK IN POLITICAL LAW TO EXAMINER BERNARDO PARDO
FOR RE-EVALUATION, RESULTING IN THE INCREASE OF HIS GRADE IN THAT SUBJECT FROM
57% TO 66%.
Likewise, respondent Victorio D. Lanuevo admitted having referred back the aforesaid
notebooks on Mercantile Law and Political Law respectively of Alfredo Ty dela Cruz and
Ernesto Quitaleg to the Examiners concerned.
The records are not clear, however, under what circumstances the notebooks of Ty dela
Cruz and Quitaleg were referred back to the Examiners concerned. Respondent Lanuevo
claimed that these two cases were o cially brought to the Bar Examination Committee
during its rst meeting (Vol. VI, pp. 50-51, rec.) and the latter decided to refer them back to
the Examiners concerned for re-evaluation with respect to the case of Quitaleg and to remove
the disquali cation in the case of Ty dela Cruz (Vol. VI, pp. 33-39, 84-86, rec.). Respondent
Lanuevo further claimed that the data of these two cases were contained in a sheet of paper
which was presented at the said rst meeting of the Committee (Vol. VI, pp. 39-43, 49-51,
rec.). Likewise a record of the dates of every meeting of the Committee was made by
respondent Lanuevo (Vol. VI, p. 28, rec.). The alleged sheet containing the data of the two
examinees and record of the dates of the meeting of the Committee were not presented by
respondent Lanuevo as, according to him, he left them inadvertently in his desk in the
Con dential Room when he went on leave after the release of the Bar results (Vol. VI, pp. 28,
41-45, rec.). It appears, however, that the inventory conducted by o cials of the Court in the
Con dential Room of respondent Lanuevo did not yield any such sheet or record (Exh. X, Adm.
Case No. 1162, p. 14, rec.; Vol. VIII, pp. 11-13, 20-22, 2931, rec.).
Respondent Examiner Montecillo, Mercantile Law, maintained that there was only one
notebook in Mercantile Law which was o cially brought to him and this is substantiated by
his personal le and record (Vol. VI, pp. 34-35, rec.). According to him, this notebook's
examiner code number is 1613 (Vol. V, p. 35, rec.) and is owned by Ramon E. Galang, alias
Roman E. Galang. It appears, however, that the original grade of 47% in Mercantile Law of Ty
dela Cruz was changed to 50% as appearing in the cover of the notebook of said examinee
and the change is authenticated with the initial of Examiner Montecillo. He was present when
respondent Lanuevo presented in evidence the notebook of Ty dela Cruz bearing Examiner
Code Number 951 and O ce Code Number 110 as Exhibit 9-Lanuevo in Administrative Case
No. 1162, and the gures 47 crossed out, replaced by the gures 50 bearing the initial of
Examiner Montecillo as Exhibit 9-a-Lanuevo (Adm. Case No. 1162, p. 48, rec.; Vol. VI, pp. 23-
24, Vol. VIII, p. 4, rec.); but Atty. Montecillo did not interpose any objection to their admission
in evidence.
In this connection, respondent Examiner Pardo testi ed that he remembers a case of
an examinee presented to the Committee, who obtained passing marks in all subjects except
in one and the Committee agreed to refer back to the Examiner concerned the notebook in the
subject in which the examinee failed (Vol. V, pp. 15-16, rec.). He cannot recall the subject, but
he is certain that it was not Political Law (Vol. V, p. 16, rec.). Further, Pardo declared that he is
not aware of any case of an examinee who was on the borderline of passing but who got a
grade below 50% in one subject that was taken up by the Committee (Vol. V, pp. 16-17, rec.).
Examiner Montecillo testi ed that it was the notebook with Examiner Code Number
1613 (belonging to Galang) which was referred to the Committee and the Committee agreed
to return it to the Examiner concerned. The day following the meeting in which the case of an
examinee with Code Number 1613 was taken up, respondent Lanuevo handed him said
notebook and he accordingly re-evaluated it. This particular notebook with O ce Code
Number 954 belongs to Galang.
Examiner Tomacruz recalled a case of an examinee whose problem was Mercantile Law
that was taken up by the Committee. He is not certain of any other case brought to the
Committee (Vol. V, pp. 59-61, rec.). Pardo declared that there was no case of an examinee
that was referred to the Committee that involved Political Law. He re-evaluated the answers of
Ernesto Quitaleg in Political Law upon the representation made by respondent Lanuevo to
him.
As heretofore stated, it was this consensus at the meeting on February 8, 1972 of the
members of the Committee that where an examinee failed in only one subject and passed all
the others, the Examiner in whose subject the examinee failed should reevaluate or recheck
the notebook (Vol. V, p. 16, rec.: Exh. 2-Pardo, allegation No. 9, Adm. Case No. 1164, pp. 60-
63, Exh. A-Montecillo, Allegation No. 2, Adm. Case No. 1164, pp. 40-41, and Exh. B-Montecillo,
Adm. Case No. 1164, p. 72, rec.).
At the time the notebook of Ernesto Quitaleg in Political Law with a grade of 57% was
referred back to Examiner Pardo, said examinee had other failing grades in three (3) subjects,
as follows:
Labor Laws 73%
Taxation 69%
Mercantile Law 68%
Ernesto Quitaleg's grades and averages before and after the re-evaluation of his grade
in Political Law are as follows:
BA
Political Law 57% 66% = 9 pts. or 27
weighted points
Labor Laws 73% 73% = No reevaluation
Civil Law 75% 75% = "
Taxation 69% 69% = "
Mercantile Law 68% 68% = "
Criminal Law 78% 78% = "
Remedial Law 85% 85% = "
Legal Ethics 83% 83% = "
——————————
Average (weighted) — 73.15% — 74.5%
(Vol. VI, pp. 26-27; Exhs. 10 and 10-A-Lanuevo, Adm. Case No. 1162, rec.)
Alfredo Ty dela Cruz, at the time his notebook in Mercantile Law was referred to
Examiner Montecillo to remove the disquali cation grade of 47% in said subject, had two (2)
other failing grades. These are:
Political Law 70%
Taxation 72%
His grades and averages before and after the disqualifying grade was removed are as follows:
B A
Political Law 70% 70% = No reevaluation

Labor Laws 75% 75% = "
Civil Law 89% 89% = "
Taxation 72% 72% = "
Mercantile Law 47% 50% = 3 pts. or 9
weighted points
Criminal Law 78% 78% = no reevaluation
Remedial Law 88% 88% = "
Legal Ethics 79% 79% = "
————————————————
Weighted Averages — 74.95% — 75.4%
(Vol. VI, pp. 26-27, rec.).
The re-evaluation of the answers of Quitaleg in Political Law and the answers of Ty dela
Cruz in Mercantile Law, violated the consensus of the Bar Examination Committee in February,
1971, which violation was due to the misrepresentation of respondent Lanuevo.
It must be stated that the referral of the notebook of Galang in Mercantile Law to
Examiner Montecillo can hardly be said to be covered by the consensus of the Bar
Examination Committee because even at the time of said referral, which was after the
unauthorized re-evaluation of his answers of four (4) subjects, Galang had still failing grades
in Taxation and Labor Laws. His re-evaluated grade of 74.5% in Remedial Law was considered
75% under the Con dential Memorandum and was so entered in the record. His grade in
Mercantile Law as subsequently reevaluated by Examiner Montecillo was 71%.
Respondent Lanuevo is therefore guilty of serious misconduct — of having betrayed the
trust and con dence reposed in him as Bar Con dant, thereby impairing the integrity of the
Bar examinations and undermining public faith in the Supreme Court. He should be disbarred.
As to whether Ernesto Quitaleg and Alfredo Ty dela Cruz should be disbarred or their
names stricken from the Roll of Attorneys, it is believed that they should be required to show
cause and the corresponding investigation conducted.
III
Re: Administrative Case No. 1163, Ramon E. Galang, alias Roman E. Galang, respondent.
A
The name of respondent Ramon E. Galang, alias Roman E. Galang, should likewise be
stricken off the Roll of Attorneys. This is a necessary consequence of the un-authorized
reevaluation of his answers in ve (5) major subjects — Civil Law, Political and International
Law, Criminal Law, Remedial Law, and Mercantile Law.
The judicial function of the Supreme Court in admitting candidates to the legal
profession, which necessarily involves the exercise of discretion, requires: (1) previous
established rules and principles; (2) concrete facts, whether past or present, affecting
determinate individuals; and (3) a decision as to whether these facts are governed by the rules
and principles (In re: Cunanan — Flunkers' Petition for Admission to the Bar — 94 Phil. 534,
544-545). The determination of whether a bar candidate has obtained the required passing
grade certainly involves discretion (Legal and Judicial Ethics, Justice Martin, 1969 ed., p. 13).
In the exercise of this function, the Court acts through a Bar Examination Committee,
composed of a member of the Court who acts as Chairman and eight (8) members of the Bar
who act as examiners in the eight (8) bar subjects with one subject assigned to each. Acting
as a sort of liaison o cer between the Court and the Bar Chairman, on one hand, and the
individual members of the Committee, on the other, is the Bar Con dant who is at the same
time a deputy clerk of the Court. Necessarily, every act of the Committee in connection with
the exercise of discretion in the admission of examinees to membership of the Bar must be in
accordance with the established rules of the Court and must always be subject to the nal
approval of the Court. With respect to the Bar Con dant, whose position is primarily
con dential as the designation indicates, his functions in connection with the conduct of the
Bar examinations are defined and circumscribed by the Court and must be strictly adhered to.
The re-evaluation by the Examiners concerned of the examination answers of
respondent Galang in ve (5) subjects, as already clearly established, was initiated by
respondent Lanuevo without any authority from the Court, a serious breach of the trust and
con dence reposed by the Court in him as Bar Con dant. Consequently, the re-evaluation that
enabled respondent Galang to pass the 1971 Bar examinations and to be admitted to the Bar
is a complete nullity. The Bar Con dant does not possess any discretion with respect to the
matter of admission of examinees to the Bar. He is not clothed with authority to determine
whether or not an examinee's answers merit re-evaluation or re-correction or whether the
Examiner's appraisal of such answers is correct. And whether or not the examinee bene ted
was in connivance or a privy thereto is immaterial. What is decisive is whether the
proceedings or incidents that led to the candidate's admission to the Bar were in accordance
with the rules.
B
Section 2 of Rule 138 of the Revised Rules of Court of 1964, in connection, among
others, with the character requirement of candidates for admission to the Bar, provides that
"every applicant for admission as a member of the Bar must be . . . of good moral character . .
. and must produce before the Supreme Court satisfactory evidence of good moral character,
and that no charges against him involving moral turpitude, have been led or are pending in
any court in the Philippines." Prior to 1964, or under the old Rules of Court, a bar applicant was
required to produce before the Supreme Court satisfactory testimonials of good moral
character (Sec. 2, Rule 127). Under both rules, every applicant is duty bound to lay before the
Court all his involvement in any criminal case, pending or otherwise terminated, to enable the
Court to fully ascertain or determine applicant's moral character. Furthermore, as to what
crime involves moral turpitude, is for the Supreme Court to determine. Hence, the necessity of
laying before or informing the Court of one's personal record — whether he was criminally
indicted, acquitted, convicted or the case dismissed or is still pending — becomes more
compelling. The forms for application to take the Bar examinations provided by the Supreme
Court beginning the year 1965 require the disclosure not only of criminal cases involving
moral turpitude led or pending against the applicant but also of all other criminal cases of
which he has been accused. It is of course true that the application form used by respondent
Galang when he took the Bar for the rst time in 1962 did not expressly require the disclosure
of the applicant's criminal records, if any. But as already intimated, implicit in his task to show
satisfactory evidence or proof of good moral character is his obligation to reveal to the Court
all his involvement in any criminal case so that the Court can consider them in the
ascertainment and determination of his moral character. And undeniably, with the applicant's
criminal records before it, the Court will be in a better position to consider the applicant's
moral character; for it could not be gainsaid that an applicant's involvement in any criminal
case, whether pending or terminated by its dismissal or applicant's acquittal or conviction,
has a bearing upon his character or tness for admission to the Bar. In 1963 and 1964, when
respondent Galang took the Bar for the second and third time, respectively, the application
form provided by the Court for use of applicants already required the applicant to declare
under oath that "he has not been accused of, indicted for or convicted by any court or tribunal
of any offense involving moral turpitude; and that there is no pending case of that nature
against him." By 1966, when Galang took the Bar examinations for the fourth time, the
application form prepared by the Court for use of applicants required the applicant to reveal
all his criminal cases whether involving moral turpitude or not. In paragraph 4 of that form, the
applicant is required under oath to declare that "he has not been charged with any offense
before a Fiscal, Municipal Judge, or other o cer; or accused of, indicted for or convicted by
any court or tribunal of any crime involving moral turpitude; nor is there a pending case
against him" (Adm. Case No. 1163, p. 56, rec.). Yet, respondent Galang continued to
intentionally withhold or conceal from the Court his criminal case of slight physical injuries
which was then and until now is pending in the City Court of Manila; and thereafter repeatedly
omitted to make mention of the same in his applications to take the Bar examinations in
1967, 1969 and 1971.
All told, respondent Ramon E. Galang, alias Roman E. Galang, is guilty of fraudulently
concealing and withholding from the Court his pending criminal case for physical injuries in
1962, 1963, 1964, 1966, 1967, 1969 and 1971; and in 1966, 1967, 1969 and 1971, he
committed perjury when he declared under oath that he had no pending criminal case in court.
By falsely representing to the Court that he had no criminal case pending in court, respondent
Galang was allowed unconditionally to take the Bar examinations seven (7) times and in 1972
was allowed to take his oath.
That the concealment of an attorney in his application to take the Bar examinations of
the fact that he had been charged with, or indicted for, an alleged crime, is a ground for
revocation of his license to practice law is well — settled (see 165 ALR 1151, 7 CJS 741).
Thus:
"[1] It requires no argument to reach the conclusion that the respondent, in
withholding from the board of law examiners and from the justice of this court, to whom
he applied for admission, information respecting so serious a matter as an indictment
for a felony, was guilty of fraud upon the court (cases cited)."[2] It is equally clear that,
had the board of law examiners, or the judge to whom he applied for admission, been
apprised of the true situation, neither the certi cate of the board nor of the judge would
have been forthcoming "(State ex rel. Board of Law Examiners v. Podell, 207 N — W —
709 — 710)."
The license of respondent Podell was revoked and annulled, and he was required to
surrender to the clerk of court the license issued to him, and his name was stricken from the
roll of attorneys (p. 710).
Likewise in Re Carpel, it was declared that:
"[1] The power to admit to the bar on motion is conferred in the discretion of
the Appellate Division.' In the exercise of the discretion, the court should be informed
truthfully and frankly of matters tending to show the character of the applicant and his
standing at the bar of the state from which he comes. The finding of indictments against
him, one of which was still outstanding at the time of his motion, were facts which
should have been submitted to the court, with such explanations as were available.
Silence respecting them was reprehensible, as tending to deceive the court" (165 NYS,
102, 104; italics supplied).
Carpel's admission to the bar was revoked (p. 105).

Furthermore, respondent's persistent denial of his involvement in any criminal case
despite his having been apprised by the Investigator of some of the circumstances of the
criminal case including the very name of the victim in that case (he nally admitted it when he
was confronted by the victim himself, who was called to testify thereon), and his continued
failure for about thirteen years to clear his name in that criminal case up to the present time,
indicate his lack of the requisite attributes of honesty, probity and good demeanor. He is
therefore unworthy of becoming a member of the noble profession of law.
While this aspect of the investigation was not part of the formal resolution of the Court
requiring him to explain why his name should not be stricken from the Roll of Attorneys,
respondent Galang was, as early as August, 1973, apprised of his omission to reveal to the
Court his pending criminal case. Yet he did not offer any explanation for such omission.
Under the circumstances in which respondent Ramon E. Galang, alias Roman E. Galang,
was allowed to take the Bar examinations and the highly irregular manner in which he passed
the Bar, WE have no other alternative but to order the surrender of his attorney's certi cate
and the striking out of his name from the Roll of Attorneys. For as WE said in Re Felipe del
Rosario:
"The practice of the law is not an absolute right to be granted every one who
demands it, but is a privilege to be extended or withheld in the exercise of sound
discretion. The standards of the legal profession are not satis ed by conduct which
merely enables one to escape the penalties of the criminal law. It would be a disgrace to
the Judiciary to receive one whose integrity is questionable as an o cer of the court, to
clothe him with all the prestige of its con dence, and then to permit him to hold himself
as a duly authorized member of the Bar (citing American cases)" [52 Phil. 399-401].
What WE now do with respondent Ramon E. Galang, alias Roman E. Galang, in this
present case is not without any precedent in this jurisdiction. WE had on several occasions in
the past nulli ed the admission of successful bar candidates to the membership of the Bar on
the grounds, among others, of (a) misrepresentations of, or false pretenses relative to, the
requirement on applicant's educational attainment [Tapel vs. Publico, resolution of the
Supreme Court striking off the name of Juan T. Publico from the Roll of Attorneys on the basis
of the ndings of the Court Investigators contained in their report and recommendation, Feb.
23, 1962; In re: Telesforo A. Diao, 7 SCRA 475-478]; (black of good moral character [In re:
Peralta, 101 Phil. 313-314]; and (c) fraudulent passing of the Bar examinations [People vs.
Romualdez — re: Luis Mabunay, 57 Phil. 151; In re: Del Rosario, 52 Phil. 399 and People vs.
Castro and Doe, 54 Phil. 42]. In the cases of Romualdez (Mabunay) and Castro, the Court
found that the grades of Mabunay and Castro were falsi ed and they were convicted of the
crime of falsification of public documents.
IV
RE:Administrative Case No. 1164, Assistant Solicitor General Bernardo Pardo (now CFI
Judge), Judge Ramon Pamatian (Later Associate Justice of the Court of Appeals, now
deceased) Atty. Manuel G. Montecillo, Atty. Fidel Manalo, Atty. Manuel Tomacruz and Atty.
Guillermo Pablo, Jr., respondents.
All respondents Bar examiners candidly admitted having made the re-evaluation and/or
re-correction of the papers in question upon the misrepresentation of respondent Bar
Con dant Lanuevo. All, however, professed good faith; and that they re-evaluated or increased
the grades of the notebooks without knowing the identity of the examinee who owned the
said notebooks; and that they did the same without any consideration or expectation of any.
These the records clearly demonstrate and WE are of the opinion and WE so declare that
indeed the respondents-examiners made the re-evaluation or recorrection in good faith and
without any consideration whatsoever.
Considering however the vital public interest involved in the matter of admission of
members to the Bar, the respondents bar examiners, under the circumstances, should have
exercised greater care and caution and should have been more inquisitive before acceding to
the request of respondent Bar Con dant Lanuevo. They could have asked the Chairman of the
Bar Examination Committee, who would have referred the matter to the Supreme Court. At
least the respondents-examiners should have required respondent Lanuevo to produce or
show them the complete Fades and/or the average of the examinee represented by
respondent Lanuevo to have failed only in their respective and particular subject and/or was
on the borderline of passing to fully satisfy themselves that the examinee concerned was
really so circumstanced. This they could have easily done and the stain on the Bar
examinations could have been avoided.
Respondent Bar examiners Montecillo, Pamatian, and Manalo claimed and so declared
under oath that the answers of respondent Galang really deserved or merited the increased
grades; and so with respondent Pardo in connection with the reevaluation of Ernesto
Quitaleg's answers in Political Law. With respect to respondents Tomacruz and Pablo, it
would appear that they increased the grades of Galang in their respective subject solely
because of the misrepresentations of respondent Lanuevo. Hence, in the words of respondent
Tomacruz: "You brought to me one paper and you said that this particular examinee had
almost passed, however, in my subject he received 60 something, I cannot remember the
exact average and if he would get a few points higher, he would get a passing average. I
agreed to do that because I did not wish to be the one causing his failure. . . ." (Vol. V, pp. 60-
61, rec.; see also allegations 3 and 4, Exh. 1-Tomacruz, Adm. Case No. 1164, p. 69, rec.;
emphasis ours). And respondent Pablo: ". . . he told me that this particular examinee seems to
have passed in all other subjects except this subject and that if I can re-evaluate this
examination notebook and increase the mark to at least 75, this particular examinee will pass
the bar examinations so I believe I asked him 'Is this being done?' and he said 'Yes, that is the
practice used to be done before to help out examinees who are failing in just one subject' so I
readily acceded to his request and said 'Just leave it with me and I will try to re-evaluate' and
he left it with me and what I did was to go over the book and tried to be as lenient as I could.
While I did not mark correct the answers which were wrong, what I did was to be more lenient
and if the answer was correct although it was not complete I raise the grade so I had a total of
78 instead of 68 and what I did was to correct the grading sheet accordingly and initial the
changes" (Vol. V, pp. 44-45, rec.; emphasis supplied).
It could not be seriously denied, however, that the favorable re-evaluations made by
respondents Pamatian, Montecillo, Manalo and Pardo notwithstanding their declarations that
the increases in grades they gave were deserved by the examinee concerned, were to a certain
extent in uenced by the misrepresentation and deception committed by respondent Lanuevo.
Thus in their own words:
Montecillo —
"Q And by reason of that information you made the reevaluation of the paper?
"A Yeas, your Honor.
"Q Would you have re-evaluated the paper of your own accord in the absence of
such information?
"A No, your Honor, because I have submitted my report at that time" (Vol. V; p. 33,
rec.; see also allegations in paragraphs 2, 3, 4 & 5, A davit of April 17, 1972, Exh.
B-Montecillo; allegation No. 2, Answer dated March 19, 1973, Exh. A-Montecillo,
Adm. Case No. 1164, pp. 40-41, and 72, rec.).
Pamatian —
"3. That sometime in the later part of January of this year, he brought back to
me an examination booklet in Civil Law for reevaluation because according to him the
owner of the paper is on the borderline and if I could reconsider his grade to 75% the
candidate concerned will get passing mark;
"4. That taking his word for it and under the belief that it was really the
practice and policy of the Supreme Court to do so and in the further belief that I was just
manifesting cooperation in doing so, I reevaluated the paper and reconsidered the grade
to 75%; . . ." (Exh. 2-Pamatian, Adm. Case No. 1164, p. 55, rec.); and
"5. That the above re-evaluation was made in good faith and under the belief
that I am authorized to do so in view of the misrepresentation of said Atty. Victorio
Lanuevo, . . ." (Exh. 1-Pamatian, Adm. Case No. 1164, pp. 33-34, rec.).
Manalo —
"(c) In revising the grade of the particular examinee concerned, herein
respondent carefully evaluated each and every answer written in the notebook. Testing
the answers by the criteria laid down by the Court, and giving the said examinee the
bene t of the doubt in view of Mr. Lanuevo's representation that it was only in that
particular subject that said examinee failed, herein respondent became convinced that
the said examinee deserved a higher grade than that previously given him, but he did not
deserve, in herein respondent's honest appraisal, to be given the passing grade of 75%. . .
." (allegation 5-c, p. 38, Exh. 1-Manalo, rec.; emphasis supplied).
Pardo —
". . . I considered it entirely humanly possible to have erred, because I corrected
that particular notebook on December 31, 1971, considering especially the representation
of the Bar Con dant that the said examinee had obtained higher grades in other
subjects, the highest of which was 84% in Remedial law, if I recall correctly . . . ."
(allegation 7, Exh. 2-Pardo, Adm. Case No. 1164, p. 62, rec.; emphasis supplied).
With the misrepresentations and the circumstances utilized by respondent Lanuevo to

induce the herein examiners to make the re-evaluation adverted to, no one among them can
truly claim that the re-evaluation effected by them was impartial or free from any improper
influence, their conceded integrity, honesty and competence notwithstanding.
Consequently, Galang cannot justi ably claim that he deserved the increased grades
given after the said reevaluations (Galangs memo attached to the records, Adm. Case No.
1163).
At any rate, WE are convinced, in the light of the explanations of the respondents-
examiners, which were earlier quoted in full, that their actuations in connection with the
reevaluation of the answers of Galang in ve (5) subjects do not warrant or deserve the
imposition of any disciplinary action. WE nd their explanations satisfactory. Nevertheless,
WE are constrained to remind herein respondents-examiners that their participation in the
admission of members to the Bar is one impressed with the highest consideration of public
interest — absolute purity of the proceedings — and so are required to exercise the greatest or
utmost care and vigilance in the performance of their duties relative thereto.

V
Respondent Atty. Victorio D. Lanuevo, in his memorandum led on November 14, 1973,
claimed that respondent-examiner Pamatian "in bringing up this unfounded cause, or lending
undue assistance or support thereto . . . was motivated with vindictiveness due to
respondent's refusal to be pressured into helping his (examiner's) alleged friend — a
participant in the 1971 Bar Examinations whom said examiner named as Oscar Landicho and
who, the records will show, did not pass said examinations" (p. 9, Lanuevo's memo, Adm. Case
No. 1162).
It must be stated that this is a very serious charge against the honor and integrity of the
late Justice Ramon Pamatian, who passed away on October 18, 1973 and therefore cannot
refute Lanuevo's insinuations. Respondent Victorio D. Lanuevo did not bring this out during the
investigation which in his words is "essential to his defense." His pretension that he did not
make this charge during the investigation when Justice Pamatian was still alive, and deferred
the ling of such charge against Justice Pamatian and possibly also against Oscar Landicho
before the latter departed for Australia "until this case shall have been terminated lest it be
misread or misinterpreted as being intended as a leverage for a favorable outcome of this
case on the part of respondent or an act of reprisal", does not invite belief; because he does
not impugn the motives of the ve other members of the 1971 Bar Examination Committee,
who also a rmed that he deceived them into re-evaluating or revising the grades of
respondent Galang in their respective subjects.
It appears, however, that after the release of the results of the 1971 Bar examinations,
Oscar Landicho, who failed in that examinations, went to see and did see Civil Law Examiner
Pamatian for the purpose of seeking his help in connection with the 1971 Bar examinations.
Examiner Pamatian advised Landicho to see the Chairman of the 1971 Bar Examination
Committee. Examiner Pamatian mentioned in passing to Landicho that an examination
booklet was re-evaluated by him (Pamatian) before the release of the said bar results (Vol. V,
pp. 6-7, rec.). Even though such information was divulged by respondent Pamatian after the
o cial release of the bar results, it remains an indecorous act, hardly expected of a member
of the Judiciary who should exhibit restraint in his actuations demanded by resolute
adherence to the rules of delicacy. His unseemly act tended to undermine the integrity of the
bar examinations and to impair public faith in the Supreme Court.
VI
The investigation failed in unearth direct evidence that the illegal machination of
respondent Lanuevo to enable Galang to pass the 1971 Bar examinations was committed for
valuable consideration.
A
There are, however, acquisitions made by respondent Lanuevo immediately after the
o cial release of the 1971 Bar examinations in February, 1972, which may be out of
proportion to his salary as Bar Confidant and Deputy Clerk of Court of the Supreme Court.
1. On April 5, 1972, respondent Lanuevo and his wife acquired from the BF
Homes, Inc. a house and lot with an area of 374 square meters, more or less. for the
amount of P84,114 00. The deed of sale was dated March 5, 1972 but was notarized
only on April 5, 1972. On the same date, however, respondent Lanuevo and his wife
executed two (2) mortgages covering the said house and lot in favor of BF Homes, Inc. in
the total amount of P67,291.20 (First —mortgage P58,879.80, Entry No. 90913: date of
instrument — April 5, 1972, date of inscription — April 20, 1972; Second mortgage —
P8,411.40, Entry No. 90914: date of instrument — April 5, 1972, date of inscription — April
20, 1972). [D-2 to D-4, Vol. III, rec.]. Respondent Lanuevo paid as down payment the
amount of only P17,000.00, which according to him is equivalent to 20%, more or less, of
the purchase price of P84,114,00. Respondent Lanuevo claimed that P5,000.00 of the
P17,000.00 was his savings while the remaining P12,000.00 came from his sister in
Okinawa in the form of a loan and received by him through a niece before Christmas of
1971 in dollars ($2000) [Vol. VII, pp. 41-48; Vol. VIII, pp. 2-3, rec.]
It appears, however, that his alleged P5,000.00 savings and P12,000.00 loan from
his sister; are not fully re ected and accounted for in respondent's 1971 Statement of
Assets and Liabilities which he filed on January 17, 1972.
In said 1971 statement, respondent Lanuevo listed under Assets a bank deposit in
the amount of only P2,000.00. In his 1972 statement, his bank deposit listed under
Assets was in the amount of P1,011.00, which shows therefore that of the P2,000.00
bank deposit listed in his 1971 statement under Assets, only the amount of P989.00 was
used or withdrawn. The amount of P18,000.00 receivable listed under Assets in his 1971
statement was not realized because the transaction therein involved did not push
through (Statement of Assets and Liabilities of respondent Lanuevo from 1965 to 1972;
Vol. VIII, pp. 47-48, rec.).
Likewise, the alleged December, 1971 $2000 loan of respondent from his married
sister in Okinawa is extremely doubtful. In the rst place, said amount of $2000
(P12,000.00) is not re ected in his 1971 Statement of Assets and Liabilities led on
January 17, 1972. Secondly, the alleged note which he allegedly received from his sister
at the time he received the $2000 was not even presented by respondent during the
investigation. And according to respondent Lanuevo himself, while he considered this a
loan, his sister did not seriously consider it as one. In fact, no mode or time of payment
was agreed upon by them. And furthermore, during the investigation, respondent
Lanuevo promised to furnish the Investigator the address of his sister in Okinawa. Said
promise was not ful lled as borne out by the records. Considering that there is no
showing that his sister, who has a family of her own, is among the top earners in
Okinawa or has saved a lot of money to give to him, the conclusion, therefore, that the
P17,000.00 of respondent Lanuevo was either an ill-gotten or undeclared income is
inevitable under the foregoing circumstances.
On August 14, 1972, respondent Lanuevo and his wife mortgaged their BF Homes
house and lot to the GSIS for the amount of P65,000.00 (Entry No. 4992: August 14,
1972 — date of instrument; August 23, 1972 — date of inscription). On February 23, 1973,
t h e second mortgage in favor of BF Homes, Entry No. 90914, was redeemed by
respondent and was subsequently cancelled on March 20, 1975, Entry No. 30143.
Subsequently, or on March 2, 1973 the rst mortgage in favor of BF Homes, Entry No.
90913 was also redeemed by respondent Lanuevo and thereafter cancelled on March 20,
1973, (See D-2 to D-4, Vol. III, rec.). Hence, only the mortgage in favor of GSIS remains as
the encumbrance of respondent's house and lot. According to respondent Lanuevo, the
monthly amortization of the GSIS mortgage is P778.00 a month, but that since May of
1973, he was unable to pay the same. In his 1972 Statement of Assets and Liabilities,
which he led in connection with his resignation and retirement ( led October 13, 1972),
the house and lot declared as part of his assets, were valued at P75,756.90. Listed,
however, as an item in his liabilities in the same statement was the GSIS real estate loan
in the amount of P64,200.00 (1972 Statement of Assets and Liabilities).
2. Listed as an asset in his 1972 Statement of Assets and Liabilities is a 1956
VW car valued at P5,200.00. That he acquired this car sometime between January, 1972
and November, 1972 could be inferred from the fact that no such car or any car was
listed in his statement of assets and liabilities of 1971 or in the years previous to 1965. It
appears, however, that his listed total assets, excluding receivables in his 1971
Statement was P19,000 00, while in his 1972 (as of November, 1972) Statement, his
listed total assets, excluding the house and lot was P18,211.00, including the said 1956
VW car worth P5,200.00.
The proximity in point of time between the o cial release of the 1971 Bar
examinations and the acquisition of the above-mentioned properties, tends to link or tie
up the said acquisitions with the illegal machination committed by respondent Lanuevo
with respect to respondent Galangs examination papers or to show that the money used
by respondent Lanuevo in the acquisition of the above properties came from respondent
Galang in consideration of his passing the Bar.
During the early stage of this investigation but after the Court had informed respondent
Lanuevo of the serious irregularities in the 1971 Bar examinations alleged in Oscar Landicho's
Con dential Letter and in fact, after respondent Lanuevo had led on April 12, 1972 his sworn
statement on the matter, as ordered by the Court, respondent Lanuevo surprisingly led his
letter of resignation on October 13, 1972 with the end in view of retiring from the Court. His
resignation before he was required to show cause on March 5, 1973 but after he was
informed of the said irregularities, is indicative of a consciousness of guilt.
It must be noted that immediately after the o cial release of the results of the 1971
Bar examinations, respondent Lanuevo went on vacation and sick leave from March 16, 1972
to January 15, 1973, obtaining the cash value thereof in lump sum in the amount of
P11,000.00. He initially claimed at the investigation that he used a part thereof as a down
payment for his BF Homes house and lot (Vol. VII, pp. 40-48, rec.), which he bought on April 5,
1972.
Criminal proceedings may be instituted against respondent Lanuevo under Section 3 (a
& e) in relation to Section 9 of Republic Act No. 1379 (Anti-Graft Law) for:
"a)Persuading, inducing or in uencing another public o cer to perform an act
constituting a violation of rules and regulations duly promulgated by competent
authority or an offense in connection with the o cial duties of the latter, or allowing
himself to be presented, induced, or influenced to commit such violation or offense.
xxx xxx xxx
"(e)Causing any undue injury to any party, including the Government, or giving any
private party any unwarranted bene ts, advantage or preference in the discharge of his
o cial administrative or judicial functions through manifest partiality, evident bad faith
or gross inexcusable negligence. This provision shall apply to o cers and employees of
o ces or government corporations charged with the grant of licenses or permits or other
concessions."
Section 8 of said Republic Act No. 3019 authorizes the dismissal or removal of a public
o cer once it is determined that his property or money "is manifestly out of proportion to his
salary as such public o cer or employee and to his other lawful income and the income from
legitimately acquired property. . . ." (Sec. 2, Rep. Act 1379; Sec. 8, Rep. Act 3019).
It should he stressed, however, that respondent Lanuevo's aforementioned Statements
of Assets and Liabilities were not presented or taken up during the investigation; but they
were examined as they are part of the records of this Court.
B
There are likewise circumstances indicating possible contacts between respondent
Ramon E. Galang and/or his father and respondent Victorio D. Lanuevo before the latter
became the Bar Confidant.
1. Respondent Ramon E. Galang was a bene ciary of the G.I. Bill of Rights
educational program of the Philippine Veterans Board from his high school days — 1951 to
1955 — up to his pre-law studies at the MLQ Educational Institution (now MLQ University) —
1955 to 1958. From 1948 to 1958, respondent Victorio D. Lanuevo was connected with the
Philippine Veterans Board which is the governmental agency entrusted with the affairs of our
veterans including the implementation of the Veterans Bill of Rights. From 1955 to 1958,
respondent Lanuevo successively held the positions of Junior Investigator, Veterans Claims
Investigator, Supervising Veterans Investigator and Veterans Claims Investigator (Service
Record, p. 9, Adm. Case No. 1162). During that period of time, therefore, respondent Lanuevo
had direct contacts with applicants and bene ciaries of the Veterans Bill of Rights. Galang's
educational bene ts was approved on March 16, 1954 , retroactive as of the date of waiver —
July 31, 1951, which is also the date of filing (A, Vol. IV, rec.).
It is alleged by respondent Ramon E. Galang that it was his father who all the time
attended to the availment of the said educational bene ts and even when he was already in
Manila taking up his pre-law at MLQ Educational Institution from 1955 to 1958. In 1955,
respondent Galang was already 19 years old, and from 1957 to 1958, he was employed as a
technical assistant in the o ce of Senator Roy (Vol. V, pp. 79-80, 86-87, rec.). [Subsequently,
during the investigation, he claimed that he was the private secretary of Senator Puyat in 1957
(Vol. VI, pp. 12-13, rec.)]. It appears, however, that a copy of the notice-letter dated June 28,
1955 of the Philippine Veterans Board to the MLQ Educational Institution on the approval of
the transfer of respondent Galang from Sta. Rita Institute to the MLQ Educational Institution
effective the rst semester of the school year 1955-56 was directly addressed and furnished
to respondent Ramon E. Galang at 2292 Int. 8 Banal St., Tondo, Manila (A-12, Vol. IV, rec.).
Respondent Ramon E. Galang further declared that he never went to the O ce of the
Philippine Veterans to follow up his educational bene ts and claimed that he does not even
know the location of the said o ce. He does not also know whether bene ciaries of the G.I.
Bill of Rights educational bene ts are required to go to the Philippine Veterans Board every
semester to submit their ratings (Vol. V, p. 86, rec.). But respondent Galang admits that he
has gone to the GSIS and City Court of Manila, although he insists that he never bothered to
take a look at the neighboring buildings (Vol. V, pp. 93-94, rec.). The huge and imposing
Philippine Veterans Building is beside the GSIS building and is obliquely across the City Court
building.
2. Respondent Lanuevo stated that as an investigator in the Philippine Veterans
Board, he investigated claims for the several bene ts given to veterans like educational
bene ts and disability bene ts; that he does not remember, however, whether in the course of
his duties as veterans investigator, he came across the application of Ramon E. Galang for
educational bene ts and that he does not know the father of Mr. Ramon E. Galang and has
never met him (Vol. VII, pp. 28, 49, rec.).
3. Respondent Lanuevo, as a member of the USAFEE, belonged to the 91st Infantry
operating at Zambales and then Cabanatuan, Nueva Ecija, shortly before the war (Vol. VII, pp.
48-49, rec.). Later he joined the guerilla movement in Samar.
He used to be a member of the Philippine Veterans Legion especially while working
with the Philippine Veterans Board (Vol. VII, p. 49, rec.).
He does not know the Banal Regiment of the guerillas, to which Galang's father
belonged. During the Japanese occupation, his guerilla out t was operating in Samar only and
he had no communications with other guerilla organization in other parts of the country.
He attended meetings of the Philippine Veterans Legion in his chapter in Samar only
and does not remember having attended its meeting here in Manila, even while he was
employed with the Philippine Veterans Board. He is not a member of the Defenders of Bataan
and Corregidor (Vol. VII, p. 519 rec.).
On November 27, 1941, while respondent Lanuevo was with the Philippine Army
stationed at Camp Manacnac, Cabanatuan, Nueva Ecija, he was stricken with pneumonia and
was hospitalized at the Nueva Ecija Provincial Hospital as a result and was still con ned there
when their camp was bombed and strafed by Japanese planes on December 13, 1941 (Sworn
statement of respondent Lanuevo dated August 27, 1973, Adm. Case No. 1162, p. 46, rec.).
German Galang, father of respondent Galang, was a member of the Banal Guerilla
Forces, otherwise known as the Banal Regiment. He was commissioned and inducted as a
member thereof on January 16, 1942 and was given the rank of rst lieutenant. His unit "was
attached and served into the XI-Corps, US Army; XIII-C US Army, 43rd Div., US Army, stationed
headquarters at Sta. Rosa, Nueva Ecija and with the 38th Division US army stationed at
Corregidor in the mopping-up operations against the enemies, from 9 May 1945 date of
recognition to 31 December 1945, date of demobilization" (A davit of Jose Banal dated
December 22, 1947, Vol. IV, A-3, rec.).
It should be stressed that once the bar examiner has submitted the corrected
notebooks to the Bar Con dant, the same cannot be withdrawn for any purpose whatsoever
without prior authority from the Court. Consequently, this Court expresses herein its strong
disapproval of the actuations of the bar examiners in Administrative Case No. 1164 as above
delineated.
WHEREFORE, IN ADMINISTRATIVE CASE NO. 1162, RESPONDENT VICTORIO D.
LANUEVO IS HEREBY DISBARRED AND HIS NAME ORDERED STRICKEN FROM THE ROLL OF
ATTORNEYS, AND IN ADMINISTRATIVE CASE NO. 1163, RESPONDENT RAMON E. GALANG,
alias ROMAN E. GALANG, IS HEREBY LIKEWISE DISBARRED AND HIS NAME ALSO ORDERED
STRICKEN FROM THE ROLL OF ATTORNEYS.
Makalintal, C.J., Castro, Fernando, Barredo, Esguerra, Muñoz Palma and Aquino, JJ.,
concur.
Teehankee, J., concurs in the result.
Antonio, J., is on official leave.
Concepcion and Martin, JJ., took no part.

Respondent: en Banc

Uploaded by

Copyright:

Available Formats

Respondent: en Banc

Uploaded by

Document Information

Original Description:

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

Respondent: en Banc

Uploaded by

Copyright:

Available Formats

EN BANC

[A.C. No. 1162. August 29, 1975.]

IN RE: VICTORIO D. LANUEVO, former Bar Confidant and Deputy Clerk of

[A.C. No. 1163. August 29, 1975.]

CD Technologies Asia, Inc. © 2018 cdasiaonline.com

1. COURT PERSONNEL AND EMPLOYEES; BAR CONFIDANT; FUNCTIONS AND

Administrative proceedings against Victorio D. Lanuevo — for disbarment; Ramon E.

xxx xxx xxx

In his answer dated March 17, 1973 which he denominated as "Explanation",

CD Technologies Asia, Inc. © 2018 cdasiaonline.com

Respondent Ramon E. Galang, alias Roman E. Galang, asserted, among others;

"5.That respondent, before reading a copy of this Honorable Court's resolution

xxx xxx xxx

". . ." (Adm. Case No. 1163, pp. 100-104, rec.).

"4.Examination questions should be more a test of logic, knowledge of legal

Political Law 70% 70% = No reevaluation

Carpel's admission to the bar was revoked (p. 105).

With the misrepresentations and the circumstances utilized by respondent Lanuevo to

CD Technologies Asia, Inc. © 2018 cdasiaonline.com

CD Technologies Asia, Inc. © 2018 cdasiaonline.com

You might also like