EN BANC

[A.C. No. 1162. August 29, 1975.]

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

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

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; DISMISSAL OF PUBLIC OFFICER UNDER SECTION 8, REPUBLIC ACT NO. 3019.
Section 8 of Republic Act No. 3019 authorized the dismissal on removal of a public 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).
 In his answer dated March 19, 1973, respondent Montecillo restated the contents of his sworn
statement of April 17, 1972, and
xxx xxx xxx
"2.Supplementary to the foregoing sworn statement, I hereby state that I re-
evaluated the examination notebook of Bar Candidate No. 1613 in Mercantile Law in absolute
good faith and in direct compliance with the agreement made during one of the deliberations
of the Bar Examiners Committee that where a candidate fails in only one subject, the Examiner
concerned should make a re-evaluation of the answers of the candidate concerned, which I did.
"3.Finally, I hereby state that I did not know at the time I made the aforementioned
re-evaluation that notebook No. 1613 in Mercantile Law pertained to bar examinee Ramon E.
Galang, alias Roman E. Galang, and that I have never met up to this time this particular bar
examinee" (Adm. Case No. 1164, pp. 40-41, rec.; emphasis supplied).
In his sworn statement dated April 12, 1972, Bar Confidant Lanuevo stated:
xxx xxx xxx
"As I was going over those notebooks, checking the entries in the grading sheets and
the posting on the record of ratings, I was impressed of the writing and the answers on the 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).
In his answer dated March 19, 1973, respondent Lanuevo avers:
"That he submitted the notebooks in question to the examiners concerned in his
honest belief that the same merited re-evaluation; that in so doing, it was not his intention to
forsake or betray the trust reposed in him as bar 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, rec.; emphasis supplied).
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 I    
  1. Political Law and Public         
    International Law 68% 78% = 10 pts.
      or 30 weighted points      
B     A I    
    Labor Laws and Social        
    Legislations 67% 67% = no re-
      evaluation made.      
  2. Civil Law 64% 75% = 11 points
      or 33 weighted points.      
    Taxation 74% 74% = no re-
      evaluation made.      
  3. Mercantile Law 61% 71% = 10pts.
      or 30 weighted points.      
  4. Criminal Law 64% 75% = 11 pts. or
      22 weighted points.      
  5. Remedial Law 63.75% (64) 74.5% (75%) =  
      11 pts. or 44 weighted points.    
    Legal Ethics and Practical Exercises 81% 81% = no re
      evaluation made.      
      ———————————    
    General Weighted Averages 66.25% 74.15%    
 
Hence, by the simple expedient of initiating the re-evaluation of the answers of Galang in the 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, rec.; emphasis supplied).
With the misrepresentations and the circumstances utilized by respondent Lanuevo to induce the
herein examiners to make the re-evaluation adverted to, no one among them can truly claim that the re-
evaluation effected by them was impartial or free from any improper influence, their conceded integrity,
honesty and competence notwithstanding.
Consequently, Galang cannot 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) 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 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; Sec. 8, Rep. Act 3019).
 It should he stressed, however, that respondent Lanuevo's aforementioned Statements of Assets and
Liabilities were not presented or taken up during the investigation; but they were examined as they are part of
the records of this Court.
B
There are likewise circumstances indicating possible contacts between respondent Ramon E. Galang
and/or his father and respondent Victorio D. Lanuevo before the latter became the Bar Confidant.
1. Respondent Ramon E. Galang was a 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.
||| (In re Lanuevo, A.C. No. 1162, 1163, 1164, [August 29, 1975], 160 PHIL 935-988)