A.M. No.

1162 August 29, 1975

IN RE: VICTORIO D. LANUEVO, former Bar Confidant and Deputy Clerk of Court, respondent.
A.C. No. 1163 August 29, 1975
IN RE: RAMON E. GALANG, alias ROMAN E. GALANG, 1971 Bar Examinee, respondent.
A.M. No. 1164 August 29, 1975
IN RE: HON. BERNARDO PARDO, HON. RAMON PAMATIAN, ATTY. MANUEL TOMACRUZ, ATTY.
FIDEL MANALO and ATTY. GUILLERMO PABLO, JR., Members, 1971 Bar Examining Committee,
respondent.

Facts:

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.

Victorio Lanuevo, Bar Confidant of the 1971 Bar Examinations, Admitted having brought the
five examination notebooks of Ramon E. Galang back to the respective examiners for re-
evalution or re-checking.

The five examiners admitted having re-evaluated or re-checked the notebook delivered by the
Bar Confidant, stating that he has the authority to do the same and that the examinee
concerned failed only in his particular subject and was on the borderline of passing.

Ramon galang was able to pass the 1971 bar exam because of Lanuevo’s move but the exam
results bears that he failed in 5 subjects namely in Political Law, Civil Law, Mercantile Law,
Criminal Law & Remedial Law).

Issues:

Whether or not Victorio Lanuevo should be disbarred

Whether or not Ramon Galang should be disbarred

Whether or not the examiners be given disciplinary action

Ruling:

1. Yes. Lanuevo systematically and cleverly initiated and prepared the stage leading to the re-
evalation and/or recorrection 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.
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.

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 more than ninety
candidates who were more deservinh of reconsideration. Furthermore, 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. Thus he shall be disbarred.

2. Yes. 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 re-
evaluation of his answers in five (5) major subjects — Civil Law, Political and International Law,
Criminal Law, Remedial Law, and Mercantile Law.

Furthermore, respondent Galang continued to intentionally withhold or conceal from the Court
his pending criminal case of slight physical injuries; such is a violation of the rule that 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.

3. No. 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 that indeed the respondents-examiners made the re-evaluation or re-
correcion 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.