Case #26 (Zosa)
[A.C. No. 1163. August 29, 1975.]
IN RE: RAMON E. GALANG, alias
ROMAN E. GALANG, 1971 Bar
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 anue!o.
". Ramon #. $alang passed the 1%&1 'ar
e(amination 'ut his e(am papers )ere su'*ected
to unauthori+ed re,correction and re,e!aluation
 '-  e(aminers.
/. An in!estigation '- the 0BI re!ealed
• that Ramon Roman2Rom-3 )as a
student of School of a) of 4567
• that in Sept 89 1%%9 he )as charged
)ith the crime of slight ph-sical
in*uriesSI3 of another student of the
same uni!ersit-7
• that in a 1%&/ hearing9 he )as
confronted )ith this information 'ut
declared he does not remem'er 'eing
charged )ith the same.
;. <ictim )as summoned and narrated the case
and identified $alang as the !er- same person
charged )ith SI in that case.
. An administrati!e proceeding )as filed for his
dis'arment along )ith Bar Confidant anue!o.
ISS6#:
=hether or not $alang must 'e stric>en off in
the roll of attorne-s for concealing his case of
SI.
?#CISI@0: #S
1. 6nder Rule 1"&9 Sec " e!er- applicant is dut-
 'ound to la- 'efore the Court all his
in!ol!ement in an- criminal case9 pending or
other)ise terminated9 to ena'le the Court to
full- ascertain or determine applicants moral
character.
". As to )hat crime in!ol!es moral turpitude9 is
for the Supreme Court to determine. ence9 the
necessit- of la-ing 'efore or informing the Court
of ones personal record D )hether he )as
criminall- indicted9 acquitted9 con!icted or the
case dismissed or is still pending D 'ecomes
more compelling.
/. In 1%E/ and 1%E;9 )hen $alang too> the Bar
for the second and third time9 respecti!el-9 the
application form pro!ided '- the Court for use
of applicants alread- required the applicant to
declare under oath that he has not 'een accused
of9 indicted for or con!icted '- an- court or
tri'unal of an- offense in!ol!ing moral
turpitude7 and that there is no pending case of
that nature against him.
;. B- 1%EE9 )hen $alang too> the Bar
e(aminations for the fourth time9 the application
form prepared '- the Court for use of applicants
required the applicant to re!eal all his criminal
cases )hether in!ol!ing moral turpitude or not.
et9 $alang continued to intentionall- )ithhold
or conceal from the Court his criminal case of
slight ph-sical in*uries )hich )as then and until
no) is pending in the Cit- Court of 4anila7 and
thereafter repeatedl- omitted to ma>e mention of 
the same in his applications to ta>e the Bar
e(aminations in 1%E&9 1%E% and 1%&1.
. That the concealment of an attorne- in his
application to ta>e the Bar e(aminations of the
fact that he had 'een charged )ith9 or indicted
for9 an alleged crime9 is a ground for re!ocation
of his license to practice la) is )ell D settled.
E. 6nder the circumstances in )hich respondent
Ramon #. $alang9 alias Roman #. $alang9 )as
allo)ed to ta>e the Bar e(aminations and the
highl- irregular manner in )hich he passed the
Bar9 =# ha!e no other alternati!e 'ut to order
the surrender of his attorne-s certificate and the
stri>ing out of his name from the Roll of
Attorne-s.