In Re Investigation of Angel Parazo For Alleged Leakage of Questions in Some Subjects in The 1948 Bar Examinations Facts

In Re Investigation of Angel Parazo for Alleged Leakage of Questions in Some Subjects in the
1948 Bar Examinations
Facts:
The defendant, Angel Parazo, a duly accredited reporter of the Star Reporter, a local daily of
general publication wrote in the front page of a newspaper where it states in bold letters-
―CLAIM LEAK IN LAST BAR TEST‖ followed by another in slightly small letters- ―Applicants in
Uproar, Want Anomaly Probed: One School Favored‖. According to this article, the leakage in
some subjects in the recent bar examinations were denounced by some of the law graduates
who took part of the test to the Star Reporter. Only students of one private university in
Sampaloc had mimeographed questions on said subject fully one week before the tests. The
students who made the denunciation to the Star Reporter claim that the tests actually given
were similar in every respect to those they had seen students of this private university holding
around the city.
Thereafter, Justice Padilla, by the authority of the court, instructed Mr. Jose Dela Cruz with
assistance of Mr. E. Soriano to cite Mr. Parazo for questioning. In September 18, 1948, the
investigation of Mr. Parazo was conducted, on which he testified under oath. He admitted that
he was the author of the news item; that he wrote up the story in good faith and in a spirit of
public service; and that he knew the persons who gave him the information was given to him in
confidence and his informants did not wish their identities revealed. The investigators urged
Mr. Parazo to reveal the names of his informants so that the Supreme Court may be in the
position to start and conduct the necessary investigation in order to verify their charge and
complaint and take action against the party or parties responsible for this alleged irregularity, if
found true, but Parazo consistently refused to make the revelation. In the meantime, Justice
Montemayor issued a resolution dated October 7, 1948 authorizing Justice Montemayor to cite
Mr. Parazo before him, explain to him that the court requires him to reveal the source of his
information and of his news item, and to warn him that his refusal to make the revelation
demanded will be regarded as contempt of court.
Because of the seriousness of the matter, Parazo was advised to think it over and consider the
consequences, and if he need time within which to do this and so that he might even consult
the editor and publisher of his paper, he could be given an extension. On October 15, 1948, Mr.
Parazo appeared before the court but still declined and refused to make the revelation. At the
request of his counsel, that before this Court take action upon his refusal to reveal, he be
accorded a hearing, with the consent of the Court first obtained, a public hearing was held on
the same day, October 15, 1948 in the course of which, Attorney Serrano extensively and ably
argued the case of his client, invoking the benefits of Republic Act No. 53, the first section
provides that The publisher, editor or duly accredited reporter of any newspaper, magazine or
periodical of general circulation cannot be compelled to reveal the source of any news-report
or information appearing in said publication which was related in confidence to such publisher,
editor or reporter, unless the court or a House or committee of Congress finds that such
revelation is demanded by the interest of the state.
Issue:
Whether or not, the court can compel Mr. Parazo to reveal the identities of his informants?
Ruling:
Yes, the court may demand the respondent to reveal the sources of his information, in refusing
to make the revelation which the Court required of him, he committed contempt of court. The
court orders his immediate arrest and confinement in jail for a period of 1 month.
RA No. 53 provides immunity to be accorded to a publisher, editor, or reporter of any

newspaper was absolute that under no circumstances could he be compelled to reveal his
source of information or news report. The committee however, inserted an amendment by
adding to the end of section 1 of the clause ―unless the court finds such revelation is
demanded by public interest‖. The court is satisfied with that the present case easily comes
under the phrase ―interest of the state.‖ Under Article VII, section 13 of the Constitution, the
SC takes charge of the admission of members of the Philippine Bar. The Supreme Court and the
Philippine Bar have always tried to maintain a high standard for the legal profession, both in
academic preparation and legal training, as well as in honesty and fair dealing. The Court and
the licensed lawyers themselves are vitally interested in keeping this high standard; and one of
the ways of achieving this end is to admit to the practice of this noble profession only those
persons who are known to be honest, possess good moral character, and show proficiency in
and knowledge of the law by the standard set by this Court by passing the Bar Examinations
honestly and in the regular and usual manner. And one important thing to bear in mind is that
the Judiciary, from the Supreme Court down to the Justice of the Peace Courts, provincial
fiscalships and other prosecuting attorneys, and the legal departments of the Government,
draw exclusively from the Bar to fill their positions. Consequently, any charge or insinuation of
anomaly in the conduct of Bar Examinations, of necessity is imbued with wide and general
interest and national importance.

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In Re Investigation of Angel Parazo for Alleged Leakage of Questions in Some Subjects in the

1948 Bar Examinations

RA No. 53 provides immunity to be accorded to a publisher, editor, or reporter of any

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