In Re: Victorio D.

Lanuevo
A.M. No. 1162 August 29, 1975

Facts:
1. 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.
2. 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.
3. 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.
4. Upon the representation made to each of them separately and individually by the Bar Confidant,
that examiners believed that they were authorized to do so and that the examinee concerned
failed only in the examiner’s particular subject and/or was on the borderline of passing.
5. Respondent Galang declared that he does not remember having been charged with the crime of
slight physical injuries and denied any knowledge of the actuations of the Bar Confidant.

Issues:
1. Whether or not the Lanuevo has the authority to ask bar examiners to re-evaluate and re-
correct the examination result of a bar candidate.

Held:
1. No. The Court held that 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corrected notebooks to the Bar Confidant, the same cannot be withdrawn for any purpose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.
2. His duty as a Bar Confident is limited only as a custodian of the examination notebooks after
they are corrected by the examiners where he is tasked to tally the general average of the bar
candidate. He has breached the trust and confidence given to him by the court and was
disbarred with his name stricken out from the rolls of attorneys.
3. Galang was likewise disbarred for fraudulently concealing the criminal charges against him in his
application for the bar exam while under oath constituting perjury.
4. The court believed that the 5 bar examiners acted in good faith and thereby absolved from the
case but reminded to perform their duties with due care.