In Re: Lanuevo 66 SCRA 254 August 29, 1975
FACTS:
This is an administrative proceeding against Victorio Lanueva who was the Bar Confidant during
the 1971 Bar Examination emanating from the revelation of one Oscar Landicho, a bar
examinee of the same bar exam, in his confidential letter that the result of the bar exam of one
of the bar examinee later identified as Ramon Galang was raised before the result was released
to make him pass the bar. Upon investigation, Bar Confidant Victorino Lanuevo admitted having
brought back the five examination notebooks for re-evaluation. It appears that each of the 5 bar
examiners were approached by Lanuevo with the examination booklet asking them to re-
evaluate the grades of the bar examiner explaining that it is a practice policy in bar exams that
he will review the grades obtained in all subjects by an examinee and when he finds a candidate
to have extraordinary high grades in other subjects and low grade in one subject he can bring it
to the examiner for reconsideration to help the candidate pass.
ISSUE:
W/N Lanuevo has the authority to ask bar examiners to re-evaluate and re-correct the
examination result of a bar candidate. NO.
RULING:
The court ruled that it is evident that Lanuevo has deceptively staged a plot to convince each
examiner individually to re-evaluate the grades of Galang in order to help him pass the bar
without prior authorization of the Court. His duty as a Bar Confident is limited only as a
custodian of the examination notebooks after they are corrected by the examiners where he is
tasked to tally the general average of the bar candidate. All requests for re-evaluation of grades
from the bar exam shall be made by the candidate themselves. With the facts fully established
that Lanuevo initiated the re-evaluation of the exam answers of Galang without the authority of
the Court, he has breached the trust and confidence given to him by the court and was
disbarred with his name stricken out from the rolls of attorneys.