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In re: Lanuevo A.M. No.

1162 August 29, 1975

Posted on June 20, 2018

Landicho wrote a confidential letter to the court about the startling 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 that year and
that there are grades in other examination notebooks in other subjects that underwent alterations to raise the grades
prior to the release of results. 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, Ramon Galang, underwent some changes which, however, were
duly initialed and authenticated by the respective examiner concerned. Each of the five 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 and/or was on the borderline of passing.

The investigation showed that the re-evaluation of the examination papers of Ramon E. Galang alias Roman Galang,
was unauthorized, and therefore he did noy obtain a passing average in the 1971 Bar Examinations.

Lanuevo admitted having brought the five examination notebooks of Ramon E. Galang back to the respective
examiners for re-evaluation or re-checking. The five examiners having re-evaluated or re-checked the notebook to him
by the Bar Confidant.

As investigator conducted by the NBI also showed that Ramon Galang was charged with the crime of slight physical
injuries committed on certain de Vera, of the same University. Confronted with this information, respondent Galang
declared that he does not remember having been charged with the crime of slight physical injuries in that case.

It must also be noted that immediately after the official release of the results of the 1971 Bar Examinations, Lanuevo
gained possession of few properties, including that of a house in V+BF Homes, which was never declared in his
declaration of assets and liabilities. But Lanuevo’s statement of assets and liabilities were not taken up during the
investigation but were examined as parts of the records of the court.


1. Whether or not Lanuevo is guilty defrauding the examiners into re-evaluating Galang’s exam notebook.

2. Whether or not Galang is guilty of fraudulently concealing and withholding from the court his pending case.


1. Yes. It is evident that Lanuevo staged the plot to convince the examiners to individually re-examine the grades of
Galang to help him pass even without the authority of the Court.

2. Yes. Ramon Galang is guilty of fraudulently concealing and withholding from the Court his pending criminal case for
physical injuries in 1961, 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. That the concealment of
an attorney of the fact that he had been charged with, or indicted for, an alleged crime, in his application to take the Bar
Exam is a ground for revocation of his license to practice law as well-settled. He is therefore unworthy of becoming a
member of the noble profession of law.