Jurisprudence: en Banc

A.C. No.
1162, 1163, 1164 | In re Lanuevo 5/16/20, 8:00 PM
JURISPRUDENCE
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Cross Reference Cited In
Synopsis Syllabus Decision

160 PHIL 935-988
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(/jurisprudences/search?
[A.C. No. 1162. August 29, 1975.]
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citation_finder=&full_text=A.C.+No.+1163&issue_no=&ponente=&syllabus=&title=&utf8=%E2%9C%93&year_end=&
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.
Search Matches RAMON PAMATIAN, ATTY. MANUEL
) * TOMACRUZ, ATTY. MANUEL
https://cdasiaonline.com/jurisprudences/28179?s_params=bfxjiMJL5iHo6yCN5pd1 Page 1 of 76
A.C. No. 1162, 1163, 1164 | In re Lanuevo 5/16/20, 8:00 PM
MONTECILLO, ATTY. FIDEL MANALO and

ATTY. GUILLERMO PABLO, JR.,
Members, 1971 Bar Examining
Committee, respondents.
SYNOPSIS
Disbarment proceedings were filed against

the Bar Confidant, Victorio Lanuevo and a 1971
bar candidate, Ramon Galang, and disciplinary
action against five bar examiners for acts and
omissions committed in the 1971 bar
examinations.
Based on a confidential letter from a bar
flunked, The Supreme Court checked the records
of the 1971 bar examinations. As a result thereof,
the grades in five 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 Confidant admitted in
his sworn statement having brought back the five
examination notebooks to the examiners for re-
evaluation. In turn, the five 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 Confidant 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 Office
of the Bar Confidant 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 Confidant was in
violation of the trust and confidence reposed in
him, disbarred the Bar Confidant 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.
SYLLABUS
1. COURT PERSONNEL AND

EMPLOYEES; BAR CONFIDANT; FUNCTIONS
AND DUTIES. — The Bar Confidant 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 confidential 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.
2. ID.; ID.; ID.; FUNCTION IN

CONNECTION WITH BAR EXAMINATIONS. —
After the connected notebooks are submitted to the
Bar Confidant 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
officer between the Court and Bar Chairman, on
the one hand, and the individual members of the
Committee, on the other, is the Bar Confidant 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 final 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 confidant 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 filed 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 (/laws/3919);
DISMISSAL OF PUBLIC OFFICER UNDER
SECTION 8, REPUBLIC ACT NO. 3019
(/laws/3919). Section 8 of Republic Act No. 3019
(/laws/3919) authorized the dismissal on removal
of a public officer once it is determined that his
property or money "is manifestly out of proportion
to his salary as such public officer 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 confidential letter to the Court for re-
correction and re-evaluation of his answers to the
1971 Bar Examinations questions, Oscar Landicho
— who flunked 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
confirmed, according to him, by the Civil Law
Examiner himself (Hon. Ramon C. Pamatian) as
well as by Bar Confidant 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
'unofficially'? Why the discrimination? Does this not
afford sufficient 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 confidential letter,
the Court checked the records of the 1971 Bar
Examinations and found that the grades in five
subjects — Political Law and Public International
Law, Civil Law, Mercantile Law, Criminal Law and
Remedial Law — of a successful bar candidate
with office 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 office code No. 954 is
one Ramon E. Galang, alias Roman E. Galang, a
perennial bar candidate, who flunked 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
Confidant Victorio D. Lanuevo and the five (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 Confidant admitted having brought the
five 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 five (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 Confidant 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 Confidant 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 five 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 filed his answer on
March 12, 1973 (Adm. Case No. 1164, p. 70, rec.)
while respondents Pardo, Pamatian, Montecillo,
Manalo and Lanuevo filed 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 filed another sworn
statement in addition to, and in amplification of, his
answer filed on March 19, 1973 (Adm. Case No.
1162, pp. 45-47, rec.). Respondent Galang filed his
unverified 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 Office 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
Office 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 Officer, 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 identified 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 affidavits 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 affidavit 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 Confidant, 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 finds 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 reflecting 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
reflecting 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 identified 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
Confidant 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 confidant 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 Confidant,
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 Confidant 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 identified or that the code
number decoded and the examinee's

name was revealed. The Bar Confidant
told me that the name of the examinee in
the case presented hearing code number
661 had not been identified 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 Confidant'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
Confidant 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
Confidant 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 Confidant 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 Confidant's assurance
was apparently regular and so appeared
to be in the regular course of official
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 Confidant was
my official 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 Confidant
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 Confidant was
riding in the official 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 Confidant 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 Confidant knew the
grades of the examinee in the other
subjects; I presumed that, as Bar
Confidant, 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 final
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 first

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 fine, I was a victim of
deception, not a party to it. I had
absolutely no knowledge of the motives of
the Bar Confidant or his malfeasance in
office, 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, affirmed in his affidavit dated April 12, 1972:
"1. . . .
"2. That about weekly, the Bar
Confidant 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 Confidant 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 justification,
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 Confidant 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 affidavit 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 Confidant 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
Confidant 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 verified 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
first time, he was not aware, not
having been apprised
otherwise, that it was not within
the authority of the Bar
Confidant 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 fiduciary 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 benefit 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, affirmed in his affidavit 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
Confidant 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).
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 first
notebook. This led me to scrutinize all the
set of notebooks. Believing that those five
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 file 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).
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 confidant 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 disqualification 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,
On August 27, 1973, during the course of
the investigation, respondent Lanuevo filed 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 Confidential
Memorandum (identified 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 office (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 first number that comes
into my sight becomes the basis
of the ticket that I buy. At that

moment, the first 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
identified 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
significant 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
first took charge of the
examinations as bar confidant

up to 1971, I either started with
the number '27' (or '227') or end
with said number. (1968 Master
List is identified and marked as
Exh. 5-Lanuevo and the figure
'27' at the beginning of the list,
as Exh. 5-a-Lanuevo; 1969
Master List as Exh. 6-Lanuevo
and the figure '227' at the
beginning of the list, as Exh. 6-
a-Lanuevo; 1970 Master List as
Exh. 7-Lanuevo and the figure
'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 significance 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
Pacific War broke out on
December 8, 1941. While I was
still confined 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 office
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
office 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 Confidential
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
Confidential 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 Office Code No. 110,
identified 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
office 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 Office Code
No. 1622 identified 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 first 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 affidavit 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 Confidant
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
official release thereof; why should it now
reconsider a 'passing' case, especially in a
situation where the respondent and the
bar confidant do not know each other and,
indeed, met only once in the ordinary
course of official 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 Confidant
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 Confidant Lanuevo as
stated in the Resolution, which are
evidently purported to show as having
redounded to the benefit 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 influence of Bar Confidant
Lanuevo would be unjustifiable, if not far
fetched. Secondly, is the fact that Bar
Confidant Lanuevo's actuations resulted in
herein Respondent's benefit an evidence
per se of Respondent's having caused
actuations of Bar Confidant 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, unfit 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 Confidant 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
Confidant, 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 Confidant, he makes a

review of the grades obtained in all subjects of the
examinees and if he finds 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 find 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 Confidant, 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 affidavit,
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 Confidant 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 Confidant 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
Office 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 finished
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
justification 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 Office
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 Confidential 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 first 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 final grade to 71%. The
matter was not however thereafter officially 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 Office 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 first 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 office 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 five
examiners concerned to re-evaluate the five
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 fifty 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 Confidential
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 Confidant
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 confidential
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 clarified 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 confidence
reposed in him by the Court and the Examiners
implicit in his position as Bar Confidant as well as
the trust and confidence that prevailed in and
characterized his relationship with the five
members of the 1971 Bar Examination Committee,
who were thus deceived and induced into re-
evaluating the answers of only respondent Galang
in five 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
five 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 five (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 first
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
1. Political Law and Public
International Law 68%
or 30 weighted points
B A
Labor Laws and Social
Legislations 67%
evaluation made.
2. Civil Law 64%
or 33 weighted points.
Taxation 74%
evaluation made.
3. Mercantile Law 61%
or 30 weighted points.
4. Criminal Law 64%
22 weighted points.
5. Remedial Law 63.75% (64)
11 pts. or 44 weighted points.
Legal Ethics and Practical Exercises 81%
evaluation made.
———————————
General Weighted Averages 66.25%
Hence, by the simple expedient of initiating

the re-evaluation of the answers of Galang in the
five (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 Office of the Bar Confidant, 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 Confidant 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 Confidant 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 confidence
reposed in him by the Court as Bar Confidant, 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 inflicted 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 figures
954, the office code number given to Galang's
notebook, unveiled for the first time by respondent
Lanuevo in his supplemental sworn statement
(Exh. 3-Lanuevo, Adm. Case No. 1162, pp. 45-47,
rec.) filed 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 first time only on
August 27, 1973 or a period of more than five (5)
months after he filed 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 officially brought to the Bar
Examination Committee during its first 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 disqualification 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 first 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
Confidential 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 officials of the Court in the
Confidential 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 officially brought to
him and this is substantiated by his personal file
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 Office Code
Number 110 as Exhibit 9-Lanuevo in Administrative
Case No. 1162, and the figures 47 crossed out,
replaced by the figures 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 testified 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 testified 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 Office 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 disqualification
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 Confidential
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 confidence reposed in him as Bar Confidant,
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 five (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 officer between the Court and the Bar
Chairman, on one hand, and the individual
members of the Committee, on the other, is the Bar
Confidant 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 final
approval of the Court. With respect to the Bar
Confidant, whose position is primarily confidential
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 five (5) subjects, as already
clearly established, was initiated by respondent
Lanuevo without any authority from the Court, a
serious breach of the trust and confidence reposed
by the Court in him as Bar Confidant.
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 Confidant 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 benefited 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 filed 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 filed 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 first 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 fitness 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 officer; 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 certificate 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 finally
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 certificate 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 satisfied 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 officer of the court, to
clothe him with all the prestige of its
confidence, 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 nullified 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 findings 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 falsified 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 Confidant
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
Confidant 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
influenced 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, Affidavit 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 benefit 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
Confidant 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,
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 justifiably

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 five (5) subjects do not
warrant or deserve the imposition of any
disciplinary action. WE find 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 filed 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 filing 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 five other members of the 1971 Bar
Examination Committee, who also affirmed 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 official 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 official
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 reflected 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 first place, said amount of
$2000 (P12,000.00) is not reflected in his
1971 Statement of Assets and Liabilities
filed 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 fulfilled 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, the 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 first 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 filed in connection

with his resignation and retirement (filed
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 official 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
Confidential Letter and in fact, after respondent
Lanuevo had filed on April 12, 1972 his sworn
statement on the matter, as ordered by the Court,
respondent Lanuevo surprisingly filed 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
official 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 (/laws/3490)) for:
"a)Persuading, inducing or
influencing another public officer to
perform an act constituting a violation of
rules and regulations duly promulgated by
competent authority or an offense in
connection with the official 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
benefits, advantage or preference in the
discharge of his official administrative or
judicial functions through manifest
partiality, evident bad faith or gross
inexcusable negligence. This provision
shall apply to officers and employees of
offices or government corporations
charged with the grant of licenses or
permits or other concessions."
Section 8 of said Republic Act No. 3019
(/laws/3919) authorizes the dismissal or removal of
a public officer once it is determined that his
property or money "is manifestly out of proportion
to his salary as such public officer or employee and
to his other lawful income and the income from
legitimately acquired property. . . ." (Sec. 2, Rep.
Act 1379 (/laws/3490); Sec. 8, Rep. Act 3019
(/laws/3919)).
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
beneficiary 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
beneficiaries of the Veterans Bill of Rights.
Galang's educational benefits 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
benefits 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 office 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 first 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 Office of the
Philippine Veterans to follow up his educational
benefits and claimed that he does not even know
the location of the said office. He does not also
know whether beneficiaries of the G.I. Bill of Rights
educational benefits 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 benefits given to
veterans like educational benefits and disability
benefits; 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 benefits 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 outfit
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 confined 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 first 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" (Affidavit 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 Confidant, 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.
1 2 (https://cdasiaonline.com/jurisprudences/7211?s_params=bfxjiMJL5iHo6yCN5pd1)
! (https://cdasiaonline.com/jurisprudences/50339?s_params=bfxjiMJL5iHo6yCN5pd1)

Jurisprudence: en Banc

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A.C. No.

1162, 1163, 1164 | In re Lanuevo 5/16/20, 8:00 PM

Cross Reference Cited In

Synopsis Syllabus Decision

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

MONTECILLO, ATTY. FIDEL MANALO and

Disbarment proceedings were filed against

mark before or after the notebooks are submitted

1. COURT PERSONNEL AND

2. ID.; ID.; ID.; FUNCTION IN

5. ID.; ID.; ID.; ACTS OF COMMITTEE

whether he was criminally indicted, acquitted,

Administrative proceedings against Victorio

afford sufficient reason for the Court en banc to go

Each of the five (5) examiners in his

the Court to verify the same and compliance came

Municipal Court of Manila committed on Eufrosino

circumstances under which they re-evaluated

found that the notebook is number '95';

"a) Since I started

xxx xxx xxx

booklet in Remedial Law

number decoded and the examinee's

"3.At the time I reviewed the

thus looked like a regular visit to me of the

"9.I quite recall that during the first

in Criminal Law would be raised a few

had done well in other subjects, but that

. . ." (Adm. Case No. 1164, pp. 74-

xxx xxx xxx

representation that it was only

"That I reviewed the who]e paper

"As I was going over those

"It was to at least minimize the

undermine his integrity because he did it

of the ticket that I buy. At that

examinations as bar confidant

for me having been saved from

"3. That the alleged

the original grade of 57%

and the answers on the first notebook" as

fact, the respondent never knew this man

which only goes to show said narration of

representations that as Bar Confidant, he makes a

Thereafter, about the latter part of January,

"4.Examination questions should be

discretion. Respondent Manalo, believing that

thereby told the Bar Confidant to just leave the said

Galang, alias Roman E. Galang (Exhs. 1, 2 & 3-

candidate passed all other subjects except

Lanuevo had with him on that occasion an

likewise beyond dispute that he had no authority

But as openly admitted by him in the course

misrepresentations and deceptions committed by

and Practical Exercises, a minor subject, with a

Hence, by the simple expedient of initiating

notebook was re-evaluated for each of the latter

which could be more properly claimed as