Case#26(Zosa)
[A.C.No.1163.August29,1975.]
INRE:RAMONE.GALANG,alias for the Supreme Court to determine. Hence, the
ROMANE.GALANG,1971Bar necessity of laying before or informing the Court
Examinee,respondent.
Topic: Requirements for application to the Bar
no filed or pending case of moral turpitude
FACTS:
1. The case is one of the consolidated cases in In
re Lanuevo.
2. Ramon E. Galang passed the 1971 bar
examination but his exam papers were subjected
to unauthorized re-correction and re-evaluation
by 5 examiners.
3. An investigation by the NBI revealed
that Ramon (Roman/Romy) was a student of
School of Law of MLQU;
that in Sept 8, 1959, he was charged with the
crime of slight physical injuries(SPI) of
another student of the same university;
that in a 1973 hearing, he was confronted
with this information but declared he does
not remember being charged with the same.
4. Victim was summoned and narrated the case
and identified Galang as the very same person
charged with SPI in that case.
5. An administrative proceeding was filed for his
disbarment along with Bar Confidant Lanuevo.
ISSUE:
Whether or not Galang must be stricken off in
the roll of attorneys for concealing his case of
SPI.
DECISION: YES
1. Under Rule 127, Sec 2 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.
2. As to what crime involves moral turpitude, is
of one's personal record whether he was
criminally indicted, acquitted, convicted or the
case dismissed or is still pending becomes
more compelling.
3. In 1963 and 1964, when 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."
4. 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.
Yet, 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.
5. 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.
6. 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.