IN RE: VICTORIO D.

LANUEVO
A.M. NO. 1162 AUGUST 29, 1975
IN
IN RE:
RE: RAMON
RAMON E. E. GALANG,
GALANG, ALIAS
ALIAS
ROMAN
ROMAN E. E. GALANG
GALANG
A.C.
A.C. NO.
NO. 1163
1163 AUGUST
AUGUST 29,
29, 1975
1975
IN
IN RE:
RE: HON.
HON. BERNARDO
BERNARDO PARDO,
PARDO, HON.
HON.
RAMON
RAMON PAMATIAN,
PAMATIAN, ATTY.
ATTY. MANUEL
MANUEL
TOMACRUZ,
TOMACRUZ, ATTY.
ATTY. FIDEL
FIDEL
MANALO
MANALO ANDAND ATTY.
ATTY. GUILLERMO
GUILLERMO
PABLO,
PABLO, JR.
JR.
A.C.
A.C. NO.
NO. 1164
1164 AUGUST
AUGUST 29,
29, 1975
1975
 Facts
This is an administrative proceeding against
Victorio Lanuevo who was the Bar Confidant
during the 1971 Bar Examination, emanating
from the revelation of one Oscar Landicho, a
bar examinee of the same bar exam, in his
confidential letter, stating that the result of
the bar exam of one of the bar examinees,
later identified as Ramon Galang, was raised
to make him pass the bar before the result
was released.
 Facts

Acting upon said letter, the court

called the five bar examiners and the
Bar Confidant Lanuevo to submit
their sworn statements on the matter.
 Facts
It appears that each of the five bar examiners
were approached by Lanuevo with the examination
booklet, asking them to reevaluate the grades of
the bar examiner, explaining that it is a practice
policy in bar exams that he will review the grades
obtained in all subjects by an examinee, and when
he finds a candidate to have extraordinary high
grades in other subjects and low grade in one
subject, he can bring it to the examiner for
reconsideration to help the candidate pass.
 Facts

In good faith, trust, and confidence

in the authority of Lanuevo, the
examiners reevaluated the exam of
the candidate and reconsidered the
grade they gave for each subject
matter.
 Facts

Further investigation also revealed

that Ramon Galang was charged with
the crime of slight physical injuries in
the Manila MTC, but he did not
disclose this information in his
application to take the bar
examination.
 Issue

Whether or not Lanuevo had

the authority to ask bar
examiners to reevaluate and
recorrect the examination result
of a bar candidate.
 Ruling

The court ruled that it was evident

that Lanuevo had deceptively staged a
plot to convince each examiner
individually to reevaluate the grades of
Galang in order to help him pass the bar
without prior authorization of the Court.
His duty as a Bar Confidant is limited
only as a custodian of the examination
notebooks after they are corrected by
the examiners, where he is tasked to
 Ruling
All requests for reevaluation of grades
from the bar exam shall be made by the
candidate themselves. With the facts fully
established that Lanuevo initiated the
reevaluation of the exam answers of Galang
without the authority of the Court, he has
breached the trust and confidence given to
him by the court and was disbarred, with his
name stricken out from the roll of attorneys.
 Ruling

Galang was likewise disbarred for

fraudulently concealing the criminal
charges against him in his application
for the bar exam while under oath,
constituting perjury. The court
believed that the five bar examiners
acted in good faith and thereby
absolved from the case but reminded
them to perform their duties with due