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DIGEST

In re: Lanuevo A.M. No. 1162 August


29, 1975
Posted on June 20, 2018
FACTS:

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.

ISSUES:
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.

RULING:

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.