IN RE LANUEVO

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
 Cayetano vs. Monsod

201 SCRA 210

September 1991

Facts: Respondent Christian Monsod was nominated by President Corazon C. Aquino to the position
of chairman of the COMELEC. Petitioner opposed the nomination because allegedly Monsod does
not posses required qualification of having been engaged in the practice of law for at least ten years.
The 1987 constitution provides in Section 1, Article IX-C: There shall be a Commission on Elections
composed of a Chairman and six Commissioners who shall be natural-born citizens of the
Philippines and, at the time of their appointment, at least thirty-five years of age, holders of a college
degree, and must not have been candidates for any elective position in the immediately preceding
elections. However, a majority thereof, including the Chairman, shall be members of the Philippine
Bar who have been engaged in the practice of law for at least ten years.

Issue: Whether the respondent does not posses the required qualification of having engaged in the
practice of law for at least ten years.

Held: In the case of Philippine Lawyers Association vs. Agrava, stated: The practice of law is not
limited to the conduct of cases or litigation in court; it embraces the preparation of pleadings and
other papers incident to actions and special proceeding, the management of such actions and
proceedings on behalf of clients before judges and courts, and in addition, conveying. In general, all
advice to clients, and all action taken for them in matters connected with the law incorporation
services, assessment and condemnation services, contemplating an appearance before judicial
body, the foreclosure of mortgage, enforcement of a creditor’s claim in bankruptcy and insolvency
proceedings, and conducting proceedings in attachment, and in matters of estate and guardianship
have been held to constitute law practice. Practice of law means any activity, in or out court, which
requires the application of law, legal procedure, knowledge, training and experience.

The contention that Atty. Monsod does not posses the required qualification of having engaged in
the practice of law for at least ten years is incorrect since Atty. Monsod’s past work experience as a
lawyer-economist, a lawyer-manager, a lawyer-entrepreneur of industry, a lawyer-negotiator of
contracts, and a lawyer-legislator of both rich and the poor – verily more than satisfy the
constitutional requirement for the position of COMELEC chairman, The respondent has been
engaged in the practice of law for at least ten years does In the view of the foregoing, the petition is
DISMISSED.