Case Summary (A.C. No. 1162, 1163, 1164)
Respondents and Proceedings
• Adm. Case No. 1162: Victorio D. Lanuevo – charged with unauthorized intervention and manipulation of bar grades
• Adm. Case No. 1163: Ramon E. Galang – charged with benefiting from irregular grade alterations and concealing a criminal case
• Adm. Case No. 1164: Six bar examiners – charged with disciplinary action for having re-evaluated papers upon Lanuevo’s representations
Key Dates
• 1971 Bar Examinations administered October–December 1971
• Confidential tip by Oscar Landicho received March 29, 1972
• Court resolution ordering show-cause notices issued March 5, 1973
• Joint investigation conducted July 17–October 2, 1973
• Decision rendered March 1976
Applicable Law
• 1973 Philippine Constitution (in force at decision date)
• Rule 138, Revised Rules of Court (1964) – requirements for bar admission and good moral character
• Republic Act No. 1379 (Anti-Graft and Corrupt Practices Act) and R.A. 3019 – for possible graft or unexplained wealth
Facts and Investigation
- Confidential letter alleged that Civil Law grades for at least one candidate had been raised before results were released, suggesting unauthorized alterations.
- Court audit found five major subjects of bar candidate No. 954 (Galang) had been re-evaluated and initialed by examiners after notebooks had been submitted to the Court.
- Sworn statements from Lanuevo and the six examiners confirmed that Lanuevo had retrieved Galang’s notebooks and misrepresented to each examiner that Galang was “on the borderline” or failed only that subject, inducing reevaluation.
Unauthorized Reevaluation Scheme
• Civil Law (Pamatian): Grade raised from 64% to 75%
• Remedial Law (Manalo): Grade raised from 63.75% to 74.5%
• Political & Public International Law (Pablo): Grade raised from 68% to 78%
• Criminal Law (Tomacruz): Grade raised from 64% to 75%
• Mercantile Law (Montecillo): Grade raised from 61% to 71%
Resulting general average increased from 66.25% to 74.15%. A court resolution set 74% as the passing mark.
Involvement of Quitaleg and Ty dela Cruz
• Quitaleg’s Political Law grade was raised from 57% to 66% after similar misrepresentation; final average improved from 73.15% to 74.5%.
• Ty dela Cruz’s Mercantile Law grade was raised from 47% to 50%, removing a disqualification and raising the average from 74.95% to 75.4%.
Examinees’ Concealment of Criminal Case
• Galang had a pending slight physical injuries charge since 1959, which he omitted from seven successive bar applications.
• He denied knowledge of the case under oath, constituting false representation and perjury, and violating character requirements for admission.
Conduct of Bar Examiners
• All six examiners acted upon Lanuevo’s misrepresentations, professed good faith, and had no prior authorization to re-evaluate submitted notebooks.
• Court found their motive not corrupt but their failure to verify the Bar Confidant’s alleged authority or to consult the Chairm
Case Syllabus (A.C. No. 1162, 1163, 1164)
Background and Parties
- Consolidated administrative proceedings before the Supreme Court En Banc under Adm. Case Nos. 1162, 1163, and 1164, decided August 29, 1975.
- Respondents:
• Adm. Case No. 1162: Victorio D. Lanuevo, Bar Confidant and Deputy Clerk of Court.
• Adm. Case No. 1163: Ramon E. Galang, alias Roman E. Galang, 1971 bar passer.
• Adm. Case No. 1164: Hon. Bernardo Pardo, Hon. Ramon C. Pamatian, Atty. Manuel C. Tomacruz, Atty. Manuel G. Montecillo, Atty. Fidel Manalo, and Atty. Guillermo Pablo, Jr., members of the 1971 Bar Examining Committee.
Confidential Letter and Supreme Court’s Inquiry
- Oscar Landicho, a perennial bar examinee, wrote a confidential letter (March 29, 1972) alleging off-record grade changes in 1971 Bar exams.
- He cited a Civil Law examiner’s confirmation and Bar Confidant Lanuevo’s admissions.
- Landicho urged the Court en banc to investigate possible discrimination and unauthorized grade alterations.
Supreme Court’s Initial Action
- The Court examined the 1971 Bar records and found grade changes in five subjects of candidate with Office Code No. 954 (Ramon E. Galang).
- Examiners had initialed and authenticated the revisions without formal motions from examinees.
- The Court directed sworn statements from Lanuevo and the five examiners; a prima facie case led to show‐cause orders (March 5, 1973).
Unauthorized Reevaluation of Bar Examination Notebooks
- Bar Confidant Lanuevo admitted bringing five of Galang’s notebooks back to respective examiners for re-evaluation.
- Each examiner, misled to believe that the examinee had failed only in one subject or was “on the borderline,” increased Galang’s grades.
- Subjects re-evaluated and grade increases:
• Political Law & Public International Law: 68% → 78%
• Civil Law: 64% → 75%
• Mercantile Law: 61% → 71%
• Criminal Law: 64% → 75%
• Remedial Law: 63.75% → 74.5% (considered 75%)
Administrative Case No. 1162: Lanuevo’s Misconduct
- Lanuevo acted on his own initiative without Court or Committee authorization.
- He exploited trust as Bar Confidant, selectively referring only Galang’s papers despite other borderline cases.
- Misrepresentations induced each examiner to perform unauthorized re-e