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Case #26 (Zosa)

[A.C. No. 1163. August 29, 1975.]  2. As to what crime involves moral turpitude, is


for the Supreme Court to determine. Hence, the
IN RE: RAMON E. GALANG, alias  necessity of laying before or informing the Court
ROMAN E. GALANG, 1971 Bar  of one's personal record — whether he was
Examinee, respondent.  criminally indicted, acquitted, convicted or the
case dismissed or is still pending — becomes
Topic: Requirements for application to the Bar – more compelling.
no filed or pending case of moral turpitude
3. In 1963 and 1964, when Galang took the Bar
FACTS: for the second and third time, respectively, the
1. The case is one of the consolidated cases in In application form provided by the Court for use
re Lanuevo. of applicants already required the applicant to
declare under oath that "he has not been accused
2. Ramon E. Galang passed the 1971 bar of, indicted for or convicted by any court or
examination but his exam papers were subjected tribunal of any offense involving moral
to unauthorized re-correction and re-evaluation turpitude; and that there is no pending case of
by 5 examiners. that nature against him."

3. An investigation by the NBI revealed 4. By 1966, when Galang took the Bar
 that Ramon (Roman/Romy) was a examinations for the fourth time, the application
student of School of Law of MLQU; form prepared by the Court for use of applicants
 that in Sept 8, 1959, he was charged required the applicant to reveal all his criminal
with the crime of slight physical cases whether involving moral turpitude or not.
injuries(SPI) of another student of the Yet, Galang continued to intentionally withhold
same university; or conceal from the Court his criminal case of
 that in a 1973 hearing, he was slight physical injuries which was then and until
confronted with this information but now is pending in the City Court of Manila; and
declared he does not remember being thereafter repeatedly omitted to make mention of
charged with the same. the same in his applications to take the Bar
examinations in 1967, 1969 and 1971.
4. Victim was summoned and narrated the case
and identified Galang as the very same person 5. That the concealment of an attorney in his
charged with SPI in that case. application to take the Bar examinations of the
fact that he had been charged with, or indicted
5. An administrative proceeding was filed for his for, an alleged crime, is a ground for revocation
disbarment along with Bar Confidant Lanuevo. of his license to practice law is well — settled.

ISSUE: 6. Under the circumstances in which respondent


Whether or not Galang must be stricken off in Ramon E. Galang, alias Roman E. Galang, was
the roll of attorneys for concealing his case of allowed to take the Bar examinations and the
SPI. highly irregular manner in which he passed the
Bar, WE have no other alternative but to order
DECISION: YES the surrender of his attorney's certificate and the
1. Under Rule 127, Sec 2 every applicant is duty striking out of his name from the Roll of
bound to lay before the Court all his Attorneys.
involvement in any criminal case, pending or
otherwise terminated, to enable the Court to
fully ascertain or determine applicant's moral
character.