Philippine Bar Examinations: Difference between revisions
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*Virgilio B. Gesmundo (1977) |
*Virgilio B. Gesmundo (1977) |
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*Gregorio M. Batiller Jr. (1979) |
*Gregorio M. Batiller Jr. (1979) |
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*Joseph San Pedro (1991) - renounced |
*Joseph P. San Pedro (1991) - renounced |
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*Cesareo Antonio S. Singzon, Jr. (2010) |
*Cesareo Antonio S. Singzon, Jr. (2010) |
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Revision as of 03:29, 7 March 2012
The Philippine Bar Examination is the professional licensure examination for lawyers in the Philippines.
It is the only professional licensure exam in the country that is not supervised by the Professional Regulation Commission. The exam is exclusively administered by the Supreme Court of the Philippines through the Supreme Court Bar Examination Committee.
Brief history
The first bar exam was held in 1900, with 13 examinees, while the 2008 bar examination is the 107th (given per Article 8, Section 5, 1987 Constitution). The 2001 bar exam had the highest number of passers—1,266 out of 3,849 examinees, or 32.89%, while 2006 had the highest examinees -.6,187. However, the Supreme Court of the Philippines' Office of the Bar Confidant announced that (a new and official record of) 6,533 law graduates will take the 2008 Bar examinations.[1]
The most notable was the 1999 bar examinations which recorded the lowest passing rate of 16.59% or with a total number of 660 successful examinees. Also, the 2003 bar exam was marred by controversy when the Court ordered a retake of the Mercantile law due to questionnaire leakage.[2] In 2005, the High Tribunal implemented the "five-strike" rule, which disqualifies five-time flunkers from taking future bar exams.[3]
Admission requirements
A bar candidate must meet the following academic qualifications:
- Holder of a professional degree in law from a recognized law school in the Philippines[4]
- Holder of a bachelor's degree with academic credits in certain required subjects from a recognized college or university in the Philippines or abroad.[5]
He or she should also meet certain non-academic requisites:[6]
- A Filipino citizen.
- At least twenty-one (21) years of age.
- A resident of the Philippines.
- Satisfactory evidence of good moral character (usually a certificate from the dean of law school or an immediate superior at work).
- No charges involving moral turpitude have been filed against the candidate or are pending in any court in the Philippines.
In March 2010 the Philippine Supreme Court Issued Bar Matter 1153 amending provisions in sec 5 and 6 of rule 138 of the rules of court now allowing Filipino foreign law school graduates to take the bar exam provided that they comply with the following: a. completion of all courses leading to a degree of Bachelor of laws or its equivalent b. recognition or accreditation of the law school by proper authority c. completion of all fourth year subjects in a program of a law school duly accredited by the Philippine Government d. present proof of completing a separate bachelors degree
Committee of Bar Examiners
The Supreme Court appoints memberships in the Committee of Bar Examiners, the official task force for formulating bar exam questions, instituting policy directives, executing procedures, grading bar examination papers, and releasing the results of the annual bar examination.[7]
The committee is chaired by an incumbent Justice of the Supreme Court, who is designated by the Supreme Court to serve for a term of one year. The members of the committee includes eight (8) members of the Integrated Bar of the Philippines, who also hold office for a term of one year.[8] While the Justice who shall act as Chairman is immediately known, committee members must exert every effort to conceal their identities until the oath-taking of the successful bar examinees, approximately six months after the bar exam.[9]
Bar review programs
Candidates who meet all the admission requirements usually enroll in special review classes after graduating from law school. These programs are held from April to September in law schools, colleges, universities, and review centers.
Program schedule, content, and delivery differs from one review program to another. Lecturers in these programs are called bar reviewers. They are usually full-time professors and part-time professorial lecturers in law schools and universities. Most review programs invite incumbent and retired justices and high ranking public officials both as a marketing tool and as a program innovation.[10]
Venue and itinerary
In recent years, the examinations were held during the four Sundays of September of every year at the campus of De La Salle University-Manila along Taft Avenue, Manila. Starting 2011, the exams will be moved to November, and will be held at the University of Santo Tomas' campus along España Boulevard, in Sampaloc, Manila.
On February 8, 2011, the Supreme Court resolved to approve changes to the Rules of Court, thereby altering the schedule for the examinations.[11] The schedule is now as follows:
- First Sunday:
- Political and International Law, Labor and Social Legislation (morning session)
- Taxation (afternoon session)
- Second Sunday:
- Civil Law (morning session)
- Mercantile Law (afternoon session)
- Third Sunday:
- Remedial Law, Legal Ethics (morning session)
- Criminal Law (afternoon session)
- Fourth Sunday:
- Trial Memorandum (morning session)
- Legal Opinion with one legal form (afternoon session)
Coverage
The examination covers the following topics, popularly known as the bar subjects:[12]
- Political and Public International Law
- Constitutional Law
- Political Law
- Administrative Law (only the basic doctrines, excluding implementing rules and regulations of government agencies)
- Law on Public Officers
- Public Corporations
- Suffrage
- Public International Law
- Labor and Social Legislation
- Labor Law (Labor Code of the Philippines, excluding the implementing rules and regulations)
- Social Legislation
- Social Security Law
- Revised Government Service Insurance Act of 1977 (including Employees Compensation Act of 1977)
- Comprehensive Agrarian Reform Law
- Civil Law
- Civil Code of the Philippines (excluding the Code of Muslim Personal Laws, Water Code, Rental Law, Law on Sale of Subdivision of Lots and Condominiums)
- Family Code of the Philippines (including the Child and Youth Welfare Code)
- Property Registration Decree (excluding the Public Land Law)
- Conflict of Laws (Private International Law)
- Taxation
- General principles of Taxation
- Republic Act No. 1125, creating the Court of Tax Appeals
- National Internal Revenue Code (including the Expanded Value Added Tax or EVAT)
- Tariff and Customs Code (excluding Arrastre and Classification of Commodities)
- Mercantile Law
- Negotiable Instruments Law and Other Allied Laws
- Negotiable Instruments Law (with the Uniform Currency Act)
- Merchants and Commercial Transactions (including Articles 1 to 63 of the Code of Commerce, Retail Trade Law, Bulk Sales Law)
- Letters of Credit under the Code of Commerce
- Insurance Code
- Transportation Laws
- Common Carriers (Articles 1732 to 1766 of the New Civil Code)
- Commercial Contracts for Transportation Over Land (Articles 349 to 379 of the Code of Commerce)
- Maritime Commerce
- Public Service Act
- Corporation Law
- Corporation Code
- Securities Act
- Banking Laws
- Laws on Secrecy of Bank Deposits
- Deposit Insurance Corporation
- Trust Receipts Law (excluding the General Banking Act)
- Other Special Laws
- Chattel Mortgage Law
- Warehouse Receipts Law
- Laws on Intellectual Creations
- Copyright Law
- Patent Law
- Trademark Law
- Insolvency Law
- Truth in Lending Act
- Negotiable Instruments Law and Other Allied Laws
- Criminal Law
- Revised Penal Code (Books I & II excluding penalties for specific felonies)
- Indeterminate Sentence Law
- Probation Law
- Anti-Graft and Corrupt Practices Act
- Anti-Fencing Law
- Bouncing Checks Law
- Dangerous Drugs Act of 1972
- Heinous Crimes Law (excluding penalties)
- Remedial Law
- Revised Rules of Court
- 1991 Revised Rule on Summary Procedure
- Local Government Code on Conciliation Procedures (Chapter VII)
- Judiciary Reorganization Act of 1980 (excluding purely administrative provisions, Military Justice Law, Judiciary Act of 1948, and the Law Reorganizing the Court of Agrarian Relations)
- Legal Ethics and Practical Exercises
- Legal Ethics
- Judicial Ethics
- Code of Professional Responsibility
- Grievance Procedures (Rules 139-B, Revised Rules of Court)
- Forms
Grading system
The eight bar subjects are separately graded. Each subject contributes to the general average in the following proportion:[13]
Subject | Weight' |
---|---|
Civil Law | 15% |
Labor Law and Social Legislation | 10% |
Mercantile Law | 15% |
Criminal Law | 10% |
Political and International Law | 15% |
Taxation | 10% |
Remedial Law | 20% |
Legal Ethics and Practical Exercises | 5% |
The passing average fixed by law is 75%, with no grade falling below 50% in any bar subject.[14]
Passing average vs. Passing rate
The passing average is the minimum grade in the exam required to be admitted to the practice of law. The passing rate is the proportion of total number of bar passers in relation to the total number of bar examinees. It is usually computed on two levels—the national level (national bar passing rate), and the law school level (law school passing rate).
In the past, passing averages were considerably lower to admit more new lawyers (i.e. 69% in 1947, 69.45% in 1946, 70% in 1948). Since 1982, the passing average has been fixed at 75%. This has led to a dramatic decrease in the national passing rate of bar examinees, from an all-time high of 75.17% in 1954 to an all-time low of 16.59% in 1999 (all-time low should have been the single digit 5% national passing rate for the 2007 bar examination if the Supreme Court did not lower the passing average to 70% and lowered the disqualification rate in 3 subjects). In recent years, the annual national bar passing rate ranges from 20% to 30%.[15]
Passing Percentage (1978-2011)
Year | Passing Percentage |
---|---|
2011 | 31.95% (1,913 out of 5,987) |
2010 | 20.26% (982 out of 4,847) |
2009 | 24.58% (1,451 out of 5,903) |
2008 | 20.58% (1,310 out of 6,364) |
2007 | 22.91% (1,289 out of 5,626) |
2006 | 30.60% (1,893 out of 6,187) |
2005 | 27.22% (1,526 out of 5,607) |
2004 | 31.61% (1,659 out of 5,249) |
2003 | 20.71% (1,108 out of 5,349) |
2002 | 19.68% (917 out of 4,659) |
2001 | 32.89% (1,266 out of 3,849) |
2000 | 20.84% (979 out of 4,698) |
1999 | 16.59% (660 out of 3,978) |
1998 | 39.63% |
1997 | 18.11% (710 out of 3,921) |
1996 | 31.21% (1,217 out of 3,900) |
1995 | 30.90% (987 out of 3,194) |
1994 | 30.87% |
1993 | 21.65% |
1992 | 17.25% |
1991 | 17.81% (569 out of 3,194) |
1990 | 27.94% (866 out of 3,100) |
1989 | 21.22% (639 out of 3,012) |
1988 | 24.26% (689 out of 2,840) |
1987 | 16.95% (480 out of 2,832) |
1986 | 18.88% (491 out of 2,600) |
1985 | 25.78% (701 out of 2,719) |
1984 | 21.80% (563 out of 2,582) |
1983 | 21.30% (523 out of 2,455) |
1982 | 20.50% (433 out of 2,112) |
1981 | 43.71% (841 out of 1,924) |
1980 | 33.61% (605 out of 1,800) |
1979 | 49.51% (903 out of 1,824) |
1978 | 56.93% (1,076 out of 1,890) |
Law school passing rates
Law schools with the highest bar passing rates from 1996 to 2005 include:
Schools with more than 30 examinees:
- Ateneo de Manila Law School - 89.19%
- San Beda College of Law - 85.27%
- University of the Philippines College of Law - 85.19%
- University of Santo Tomas Faculty of Civil Law - 56.70%
- Far Eastern University Institute of Law - 26.25%
- University of the East College of Law - 26.23%
Schools with 30 or less examinees:
- Ateneo de Davao College of Law - 65.57%
- University of San Carlos - 54.45%
- Arellano University - 46.18%
- Pamantasan ng Lungsod ng Maynila, College of Law - 41.26%
- Xavier University – Ateneo de Cagayan - 37.45%
- Lyceum of the Philippines University - 32.40%
- Saint Louis University - 31.38%[15]
In 2009, the Commission on Higher Education revealed its list of top law schools based on average passing percentage, regardless of the number of candidates. The top 10 schools of that list are:
- Ateneo de Manila Law School – 91.24%
- San Beda College of Law – 88.4%
- University of the Philippines College of Law – 82.85%
- Far Eastern University-De La Salle University (Juris Doctor MBA) – 77.42%
- Ateneo de Davao College of Law – 75.92%
- University of San Carlos – 68.2%
- University of Santo Tomas Faculty of Civil Law – 67.64%
- University of Cebu--52.81%
- University of Perpetual Help-Rizal – 50.81%
- Arellano University – 49.3%[18]
Role of the Supreme Court, Criticisms
In 2007, only 5% (of the 5,626 who took the 2007 tests, or less than 300) got the passing grade of 75%. Thus, the Supreme Court adjusted the standard to 70% and the disqualification rate in 3 subjects (civil, labor and criminal law) from 50 to 45%. Accordingly, 1,289 or 22.91%, “passed.” This passing grade reduction is highly unusual, since it last happened in the 1981 exam when the passing grade was lowered to 72.5%. Prior to 1982, the passing mark jumped unpredictably from year to year: 69.45 percent in 1946; 69 in 1947; 70 in 1948, 1963, 1972 and 1974; 71 in 1961; 71.5 in 1953, 1964 and 1965; 72 in 1957, 1958, 1959, 1960 and 1967; 72.5 in 1954, 1962 and 1981; 73 in 1950, 1956, 1968, 1969, 1970, 1975, 1978 and 1980; 73.5 in 1955 and 1979; 74 in 1949, 1951, 1952, 1966, 1971, 1973 and 1977; and 74.5 in 1976. In 1954, the Court lowered the passing grade to 72.5%, even if the passing percentage was already at its highest at 75.17%. In 1999, moves to lower the passing grade to 74% failed, after Justice Fidel Purisima, bar committee chairman failed to disclose that his nephew took the examination. He was censured and his honoraria was reduced to half.[19]
Bar topnotchers
Bar topnotchers are bar examinees who garnered the highest bar exam grades in a particular year. Every year, the Supreme Court releases the bar top ten list. The list contains the names of bar examinees who obtained the ten highest grades. It is possible for more than ten examinees to place in the top ten because numerical ties in the computation of grades usually occur.[20]
From 1913 to 2011, schools which have produced bar topnotchers (1st placers) are as follows:[20]
- University of the Philippines College of Law - forty-six (46) bar topnotchers
- Ateneo de Manila Law School - twenty (20) bar topnotchers
- San Beda College of Law - seven (7) bar topnotchers
- Philippine Law School - five (5) bar topnotchers
- University of Manila College of Law - four (4) bar topnotchers
- Far Eastern University Institute of Law - four (4) bar topnotchers
- University of Santo Tomas Faculty of Civil Law - three (3) bar topnotchers
- University of the Cordilleras (formerly Baguio Colleges Foundation) College of Law - two (2) bar topnotchers
- Manila Law College Foundation (formerly Escuela de Derecho de Manila) - one (1) bar topnotcher
- Manuel L. Quezon University College of Law - one (1) bar topnotcher
- Holy Name University (formerly Divine Word College of Tagbilaran) - one (1) bar topnotcher
- University of the East College of Law - one (1) bar topnotcher
- San Sebastian College - Recoletos - one (1) bar topnotcher
- Arellano University School of Law - one (1) bar topnotcher
Two bar examinees topped the bar exams without officially graduating from any Philippine law school:[20]
- Jose W. Diokno - former Senator of the Philippines; 1st placer, 1945 bar exams. Mr. Diokno, who tied for Number One with Mr. Jovito Salonga in the 1945 Bar Exams, would have graduated from the University of Santo Tomas had not World War II supervened. Mr. Diokno's success in the bar exams is further underscored by the fact that he was also under-age[21] and that he also placed number 1 in the 1940 CPA Board exams which he took while in law school, after graduating summa cum laude from then De La Salle College at the age of 17. This double number 1 feat may never be paralleled. The closest may have been Cesar L. Villanueva (from the Ateneo Law School) who placed second in the 1981 Bar Exams and second again in the 1982 CPA Board Exams.
- Carolina C. Griño-Aquino - former Associate Justice of the Supreme Court; 1st placer, 1950 bar exams. Ms. Aquino (who later became the wife of Mr. Ramon Aquino, 6th placer in 1939 Bar Exams) was a special student of the UP College of Law, where she finished her last two years of law school having taken her first two years of law school at the Colegio de San Agustin in Iloilo. Ms. Aquino was advised to take her last two years of law school in UP by Colegio de San Agustin Law Dean Felipe Ysmael. Coincidentally, Mr. Ysmael (a UP Law graduate himself) placed number 1 in the 1917 Bar Exams. Since Ms. Aquino only took her last two years of law at UP, she can't be certified as an official UP law graduate.[21] Both spouses Aquino (in addition to being topnotchers) also served as Justices of the Supreme Court.[22]
In the past, non-law school graduates were allowed to take the bar. However, the Revised Rules of Court and Supreme Court Circulars allow Filipino graduates of Philippine law schools (and subject to certain conditions, Filipino graduates of foreign law schools) to take the bar, necessarily excluding non-law graduates and foreigners who have law degrees from taking part in the exercise.[4]
While not a guarantee for topping the bar, academic excellence in law school is a good indicator of an examinee's fortune in the bar exams. Ateneo Law School's only summa cum laude graduate, Claudio M. Teehankee, placed number one in the 1940 Bar Exams.[20] It is worth noting that Teehankee's son, Manuel Antonio, followed in his footsteps by graduating at the top of his Ateneo Law School class (albeit, not as summa cum laude) and placing first in the 1983 bar exams. Claudio's nephew, Enrique (a cum laude graduate from the UP College of Law), also placed number one in the 1976 bar exams. Claudio eventually became Supreme Court Chief Justice, Manuel was formerly Department of Justice Undersecretary and currently Philippine Special Envoy for International Trade as well Permanent Representative to the World Trade Organization in Geneva, Switzerland while Enrique is a successful private practitioner.
This father-son-nephew feat has yet to (and, perhaps, may never) be equalled in the annals of Philippine Bar. For siblings, the closest is when Manuel B. Zamora Jr. placed third in the 1961 Bar Exams and younger brother Ronaldo placed first in the 1969 Bar Exams.
The UST Faculty of Civil Law's sole summa cum laude graduate, Roberto B. Concepcion, placed first in the 1924 Bar Exams.[20] He later served as Chief Justice of the Supreme Court.
The San Beda College of Law's sole magna cum laude graduate, Florenz Regalado[23], ranked 1st in the 1954 Bar exams with a mark of 96.70%. The record is the highest average in the Philippine Bar Examinations, to date. Regalado later served as an Associate Justice of the Supreme Court.
The UP College of Law (which has yet to produce a summa cum laude graduate) had five of its seventeen magna cum laude graduates (the College of Law first conferred the honor to Rafael Dinglasan in 1925 and, to date, last conferred the same honor to Dionne Marie Sanchez in 2007) place number one in their respective bar exams: Rafael Dinglasan in 1925, Lorenzo Sumulong in 1929, Deogracias Eufemio in 1962, Roberto San Jose in 1966 and Ronaldo Zamora in 1969.[20] Dinglasan became a Judge of the Court of First Instance of Manila, Sumulong became Senator of the Republic and a renowned statesman, Eufemio and San Jose established their respective successful private law practices while Zamora became Executive Secretary to then President Joseph Estrada and is currently the Minority Leader in the House of Representatives.
Highest and lowest topnotcher grades
In the Philippine Bar's recorded history, the highest grade first recorded was the 92% garnered in 1913 by Manuel A. Roxas of the UP College of Law. The following year, 1914, Atty. Roxas' feat was bested by the 93% obtained by first placer Manuel C. Goyena (also from the UP College of Law). Atty. Goyena's top mark was tied by 1916-first placer Paulino Gullas (future Congressman from Cebu), another alumnus of the UP College of Law.
Another standard was created in 1940, when Claudio Teehankee (future Supreme Court Chief Justice), from the Ateneo Law School, got a grade of 94.35% when he topped the examinations. This record was obliterated four years later in 1944 when Jovito Salonga and Jose W. Diokno tied with the highest score of 95.3%. This was the first time that first place ended in a tie. When they took the 1944 Bar Exams, Atty. Salonga was an undergraduate at the UP College of Law while Atty. Diokno (future Senator) was an undergraduate of the University of Santo Tomas Faculty of Civil Law. After passing the bar, Atty. Salonga (future Senate President) went back to UP to complete his bacholer's degree in law, earning it in 1946. The only other instance of a tie at first place of the bar exams was when Edwin Enrile (salutatorian of his Ateneo Law School class) and Florin Hilbay (an honor student of the UP College of Law) both garnered the same score in 1999. Atty. Enrile served as Deputy Executive Secretary to President Gloria Arroyo and as a Professorial Lecturer at the Ateneo Law School while Atty. Hilbay is a Professor of Law at the UP College of Law.[21]
After another four years, the "bar" was raised a few notches when Manuel G. Montecillo of the Far Eastern University Institute of Law got a grade of 95.50% when he bested all the bar examinees of 1948. The following year, another record was set when Anacleto C. Mañgaser, an alumnus of the Philippine Law School, got a grade of 95.85% when he topped the 1949 bar exams.
But the diamond standard (the highest general average ever obtained among all bar topnotchers in recorded history) was set in 1954 when Florenz D. Regalado (future Supreme Court Associate Justice) of the San Beda College of Law scored 96.7% when he topped the 1954 Philippine Bar Examinations. To date, Atty. Regalado's feat remains unsurpassed and may never be equalled (much less topped).[24]
The lowest grade was obtained by Ateneo Law School's Mercedita L. Ona, 83.55%, 2008, which erased the prior record of 84.10%, obtained by Adolfo Brillantes of Escuela de Derecho de Manila (now Manila Law College Foundation) in 1920.[20][25] Atty. Ona was the just the latest of women first placers. In 1930, Tecla San Andres (an alumna of the UP College of Law and future Senator) broke the proverbial "glass ceiling" when she became the first woman to top the bar with a grade of 89.4%. Ameurfina A. Melencio (also an alumna of the UP College of Law and who later became a Justice of the Supreme Court) has the highest grade of all female bar topnotchers in recorded history, when she obtained a 93.85% rating in 1947.
Below is a listing of all 99 first-placers (from 1913 to 2011) ranked from highest to lowest in terms of rating obtained. It should be noted however that bar ratings are not exactly comparable from year-to-year as the difficulty of the exams varies through the years.
Rank | Year | Name | School | Rating |
---|---|---|---|---|
1st | 1954 | Florenz D. Regalado | San Beda College | 96.700 |
2nd | 1949 | Anacleto C. Mañgaser | Philippine Law School | 95.850 |
3rd | 1948 | Manuel G. Montecillo | Far Eastern University | 95.500 |
4th (tie) | 1944 | Jose W. Diokno | Special (University of Santo Tomas) | 95.300 |
4th (tie) | 1944 | Jovito R. Salonga | University of the Philippines | 95.300 |
6th | 1940 | Claudio Teehankee | Ateneo de Manila University | 94.350 |
7th | 1952 | Pedro Samson C. Animas | University of the Philippines | 94.250 |
8th | 1953 | Leonardo A. Amores | University of Manila | 94.050 |
9th | 1947 | Ameurfina A. Melencio-Herrera | University of the Philippines | 93.850 |
10th | 2001 | Rodolfo Ma. A. Ponferrada | University of the Philippines | 93.800 |
11th (tie) | 1914 | Manuel C. Goyena | University of the Philippines | 93.000 |
11th (tie) | 1916 | Paulino Gullas | University of the Philippines | 93.000 |
11th (tie) | 1932 | Hermenegildo Atienza | University of the Philippines | 93.000 |
14th | 2002 | Arlene M. Maneja | University of Santo Tomas | 92.900 |
15th | 1984 | Richard M. Chiu | Ateneo de Manila University | 92.850 |
16th | 1937 | Cecilia Muñoz-Palma | University of the Philippines | 92.600 |
17th | 1929 | Lorenzo S. Sumulong | University of the Philippines | 92.500 |
18th | 1978 | Cosme D. Rosell | University of the Philippines | 92.475 |
19th | 1933 | Lope C. Quimbo | University of Manila | 92.450 |
20th | 1971 | Henry R. Villarica | University of the Philippines | 92.400 |
21st | 1939 | Ferdinand E. Marcos | University of the Philippines | 92.350 |
22nd (tie) | 1951 | Vicente R. Acsay | University of Manila | 92.250 |
22nd (tie) | Aug-1946 | Gregoria T. Cruz | University of the Philippines | 92.250 |
24th | 1950 | Carolina C. Griño | Special (Colegio de San Agustin,University of the Philippines) | 92.050 |
25th (tie) | 1913 | Manuel A. Roxas | University of the Philippines | 92.000 |
25th (tie) | 1917 | Felipe Ysmael | University of the Philippines | 92.000 |
27th (tie) | 1977 | Virgilio B. Gesmundo | Ateneo de Manila University | 91.800 |
27th (tie) | 1998 | Janet B. Abuel | Baguio Colleges Foundation | 91.800 |
29th (tie) | 1934 | Miguel Aragon | University of the Philippines | 91.700 |
29th (tie) | 1960 | Ismael Andres | Manuel L. Quezon University | 91.700 |
29th (tie) | Nov-1946 | Pedro L. Yap | University of the Philippines | 91.700 |
32nd | 1974 | Arturo D. Brion | Ateneo de Manila College | 91.650 |
33rd (tie) | 1979 | Gregorio M. Batiller Jr. | Ateneo de Manila University | 91.400 |
33rd (tie) | 1983 | Manuel Antonio J. Teehankee | Ateneo de Manila University | 91.400 |
35th | 1938 | Emmanuel N. Pelaez | University of Manila | 91.300 |
36th | 1995 | Leonor Y. Dicdican | University of the Philippines | 91.200 |
37th | 1925 | Rafael Dinglasan | University of the Philippines | 91.100 |
38th (tie) | 1961 | Avelino V. Cruz | San Beda College | 90.950 |
38th (tie) | 1981 | Irene Ragodon-Guevarra | Ateneo de Manila University | 90.950 |
38th (tie) | 1982 | Ray C. Espinosa | Ateneo de Manila University | 90.950 |
41st | 1923 | Roque V. Desquitado | University of the Philippines | 90.900 |
42nd (tie) | 1962 | Deogracias G. Eufemio | University of the Philippines | 90.800 |
42nd (tie) | 1976 | Enrique Y. Teehankee | University of the Philippines | 90.800 |
44th (tie) | 1966 | Roberto V. San Jose | University of the Philippines | 90.600 |
44th (tie) | 1996 | Patricia Ann T. Prodigalidad | University of the Philippines | 90.600 |
44th (tie) | 2000 | Eliseo M. Zuñiga Jr. | University of the Philippines | 90.600 |
47th | 1955 | Tomas P. Matic Jr. | Far Eastern University | 90.550 |
48th (tie) | 1928 | Filomeno B. Pascual | Philippine Law School | 90.300 |
48th (tie) | 1973 | Vicente R. Solis | Ateneo de Manila University | 90.300 |
50th (tie) | 1941 | Emmet P.D. Shea | University of the Philippines | 90.200 |
50th (tie) | 1956 | Francisco C. Catral | San Beda College | 90.200 |
52nd | 1997 | Ma. Cecilia H. Fernandez | University of the Philippines | 90.025 |
53rd | 1915 | Francisco Villanueva Jr. | University of the Philippines | 90.000 |
54th | 1991 | Joseph P. San Pedro | Ateneo de Manila University | 89.950 |
55th (tie) | 1936 | Diosdado P. Macapagal | University of Santo Tomas | 89.850 |
55th (tie) | 1990 | Aquilino L. Pimentel III | University of the Philippines | 89.850 |
57th | 1965 | Victor S. Dela Serna | San Beda College | 89.800 |
58th | 1980 | Rafael R. Lagos | University of the Philippines | 89.750 |
59th | 1934 | Marciano P. Catral | Philippine Law School | 89.700 |
60th | 1967 | Rodolfo D. Robles | San Beda College | 89.600 |
61st (tie) | 1930 | Tecla San Andres | University of the Philippines | 89.400 |
61st (tie) | 1931 | Jose Leuterio | University of the Philippines | 89.400 |
61st (tie) | 1985 | Janette Susan L. Peña | University of the Philippines | 89.400 |
64th | 1958 | Manuel G. Abello | University of the Philippines | 89.250 |
65th (tie) | 1959 | Agustin O. Benitez | Far Eastern University | 89.200 |
65th (tie) | 1994 | Francisco Noel R. Fernandez | University of the Philippines | 89.200 |
67th | 1957 | Gregorio R. Castillo | University of the Philippines | 89.150 |
68th (tie) | 1921 | Pablo Payawal | University of the Philippines | 89.100 |
68th (tie) | 1922 | Amado L. Velilla | University of the Philippines | 89.100 |
68th (tie) | 1924 | Roberto B. Concepcion | University of Santo Tomas | 89.100 |
71st | 2010 | Cesareo Antonio S. Singzon Jr. | Ateneo de Manila University | 89.000 |
72nd | 1986 | Laurence L. Go | Ateneo de Manila University | 88.600 |
73rd | 1987 | Mario P. Victoriano | Ateneo de Manila University | 88.550 |
74th | 2003 | Aeneas Eli S. Diaz | Ateneo de Manila University | 88.530 |
75th (tie) | 1999 | Edwin R. Enrile | Ateneo de Manila University | 88.500 |
75th (tie) | 1999 | Florin T. Hilbay | University of the Philippines | 88.500 |
77th | 1964 | Jesus P. Castelo | San Beda College | 88.400 |
78th | 1993 | Anna Leah Fidelis T. Castañeda | Ateneo de Manila University | 88.325 |
79th | 1988 | Maria Yvette O. Navarro | University of the Philippines | 88.120 |
80th | 1926 | Eugeniano Perez | Philippine Law School | 88.100 |
81st | 1927 | Cesar Kintanar | University of the Philippines | 87.700 |
82nd | 2006 | Noel Neil Q. Malimban | University of the Cordilleras | 87.600 |
83rd | 1970 | Romulo D. San Juan | Far Eastern University[26] | 87.500 |
84th (tie) | 1968 | Oscar B. Glovasa | Divine World College of Tagbilaran | 87.450 |
84th (tie) | 2004 | January A. Sanchez | University of the Philippines | 87.450 |
86th | 1969 | Ronaldo B. Zamora | University of the Philippines | 87.300 |
87th | 2005 | Joan de Venecia | University of the Philippines | 87.200 |
88th | 1972 | Januario B. Soller Jr. | Ateneo de Manila University | 87.130 |
89th (tie) | 1918 | Alejo Labrador | University of the Philippines | 87.000 |
89th (tie) | 1919 | Gregorio Anonas | Philippine Law School | 87.000 |
89th (tie) | 1992 | Jayme A. Sy Jr. | Ateneo de Manila University | 87.000 |
92nd | 1975 | Nicanor B. Padilla Jr. | University of the East | 86.700 |
93rd | 1963 | Cornelio C. Gison | Ateneo de Manila University | 86.350 |
94th | 1989 | Gilberto C. Teodoro, Jr. | University of the Philippines | 86.185 |
95th | 2008 | Judy A. Lardizabal | San Sebastian College | 85.700 |
96th | 2011 | Raoul Angelo D. Atadero | Ateneo de Manila University | 85.536 |
97th | 2009 | Reinier Paul R. Yebra | San Beda College | 84.800 |
98th | 1920 | Adolfo Brillantes | Escuela de Derecho | 84.100 |
99th | 2007 | Mercedita L. Ona | Ateneo de Manila University | 83.550 |
A famous (almost anecdotal) incident in the history of the Philippine bar examinations supposedly happened in 1939 when Ferdinand Marcos topped the examinations with almost perfect score of 98.5%. However, after some deliberation on his grade (and after undergoing an oral examination before the supreme court, the result of which is impressive), the supreme court justices decide to prune down his grade to 92.35% to mitigate the effect of insinuations that he cheated on the said examinations.[27]
Highest scores in specific bar subjects
While no bar examinee has ever reached a 100% general average, several bar examinees have garnered perfect and near-perfect grades in specific bar subjects.
In 1930, Tecla San Andres-Ziga (future Senator) of the University of the Philippines got a grade of 99% in Remedial Law[28]. She also placed number one in the bar exams of the same year.
In 1949, Anacleto C. Mañgaser of the Philippine Law School earned 100% in Mercantile Law, and placed 1st in the bar exams of that year. His average of 95.85% broke all prior records before it was bested by Florenz Regalado in 1954.[20] Mañgaser's bar rating remains the second highest of all time.
In 1953, Juan Ponce Enrile (future Defense Minister and Senate President) of the University of the Philippines College of Law, where he graduated salutatorian and cum laude, earned 100% in Mercantile Law[29] and placed 11th in the bar exams of that year.[30]
In 1955, Raul Gonzales (future Congressman, Secretary of Justice and Chief Presidential Legal Counsel) of the University of Santo Tomas Faculty of Civil Law earned 99% in Remedial Law [citation needed] and 95% in International Law.[citation needed] However, he did not place in the top ten.[20]
In 1973, Renato Franciso (Executive Judge of RTC Malolos, Bulacan) of the Ateneo de Manila Law School obtained a perfect score of 100% in Criminal Law.[31]
In 1997, Maria Celia H. Fernandez of the University of the Philippines College of Law, where she graduated salutatorian and cum laude, earned 100% in Legal Ethics [citation needed] and emerged as the year's bar topnotcher.[20]
In 2001, Rodolfo Ma. A. Ponferrada, that year's valedictorian of the University of the Philippines College of Law, obtained a perfect score of 100% in Remedial Law[citation needed], the highest weighted of the bar subjects. The difference (3.75%) between his final bar examination score (93.80%) and that of the second-placer, Jesus Paolo U. Protacio (90.05%), that year's valedictorian of the Ateneo de Manila Law School and who got a perfect score of 100% in Criminal Law,[citation needed] is the highest of all time. Notably, that year's valedictorian of the San Beda College of Law, Adonis V. Gabriel, obtained a perfect score of 100% in Political Law [citation needed] and placed 8th (88.25%).[20][32] The 3.75% difference between No. 1 and No. 2 eclipsed the previous highest difference of 2.10% registered in 1966 when Roberto V. San Jose (valedictorian of the UP College of Law) garnered a grade of 90.6% versus the 88.5% of the tied second placers, Ruben F. Balane (salutatorian of the UP College of Law) and Pablo S. Trillana III (valedictorian of the San Beda College of Law).
In 2005, Gladys V. Gervacio of the University of Perpetual Help-Rizal earned a perfect 100% in two bar subjects—Legal Ethics [citation needed] and Labor Law [citation needed]. She placed 6th in the bar exams of that year. In 2011, she passed the California State Bar examinations.[20]
Increasing difficulty
The difficulty of the recent bar examinations, compared to exams of the past, can be attributed to the following factors:[15]
- The growing volume of Philippine case and statutory laws is unprecedented. Laws, jurisprudence, and legal doctrines of the past constitute only a small fraction of contemporary Philippine legal materials, which are increasing on a daily basis.[33]
- The 75% passing average with no grade lower than 50% in any subject is already fixed by law. Actual candidates who scored 74.99% in the general average were not admitted to the practice of law, unless they retake the bar exams.[15]
- The Three-Failure Rule is now in place. Candidates who have failed the bar exams for three times are not permitted to take another bar exam until they re-enroll and pass regular fourth-year review classes and attend a pre-bar review course in an approved law school.[34]
- The Five-Strike Rule is implemented since 2005. The rule limits to five the number of times a candidate may take the Bar exams. The rule disqualifies a candidate after failing in three examinations. However, he is permitted to take fourth and fifth examinations if he successfully completes a one year refresher course for each examination.[35]
- The four-year bachelor's degree is required before admission to law school. Hence, every bar examinee has to hold at least two degrees—one in law and one in another field. In the past, law schools readily admit high school graduates and two-year Associate in Arts degree holders.[36]
After the end of the Second World War, the passing rate in the succeeding years was remarkably high, ranging from 56 to 72% percent. However, after Associate Justice J.B.L. Reyes, a noted scholar, was appointed Chairman of the 1955 Bar Examinations, the passing rate for that year dropped dramatically to 26.8%, with a mortality rate of 73.2%. That ratio has been invariably maintained in the 50+ years since.[37]
Waiting period
The largely essay-type exams are manually checked by members of the Committee of Bar Examiners. Candidates have to wait from the last Sunday of the bar exams in September up to the date of the release of results, which traditionally happens before or during the Holy Week (the last week of March or the first week of April) of the following year.
During this period, candidates (who already hold law and bachelor's degrees) may opt to work in law firms and courts as legal researchers, teach in liberal arts and business colleges, function in companies and organizations using their pre-law degrees (i.e. Communication Arts, Accounting, Economics, Journalism, etc.), help run the family business, or take a long vacation.[38]
Admission of Successful Bar Examinees
The Office of the Bar Confidant of the Philippine Supreme Court releases the Official List of Successful Bar Examinees, usually during the last week of March or the first week of April of every year. Candidates whose names appear in the list are required to take and subscribe before the Supreme Court the corresponding Oath of Office.[39]
Candidates shall take an Oath of Office and sign their names in the Roll of Attorneys of the Supreme Court.[40] The oath-taking is usually held in May at the Philippine International Convention Center (PICC) with a formal program where all Justices of the Supreme Court, sitting en banc, formally approve the applications of the successful bar candidates. The eight bar examiners are officially introduced to the public. A message to the newly inducted lawyers is delivered by one of the justices. Candidates who made the bar top ten list are also introduced and honored. The deans of all Philippine law schools are requested to attend the ceremony and grace the front seats of the plenary hall.[12]
Controversies
In the 1930s, a distant relative of Imelda Romualdez Marcos who was a Justice in the High Court resigned after a controversy involving the bar examinations. Justice Ramon Fernandez was forced to protect his name and honor when he resigned because of a bar examination scandal.[1]
On November 23, 1979, the High Court, per Justice Pacifico de Castro ordered new examinations in labor and social legislation and taxation.
On May 7, 1982, 12 of the Supreme Court's 14 justices resigned amid expose "that the court fixed the bar-examination score of a member's son so that he would pass." Justice Vicente Ericta was accused to have personally approached the bar chairman to inquire whether his (Ericta's) son passed the bar. Ferdinand Marcos accepted the resignations and appointed the new Justices. Chief Justice Enrique Fernando wept at a news conference as he accepted responsibility for rechecking and changing the exam score of Gustavo Ericta, son of Justice Vicente Ericta.[41]
Associate Justice Fidel Purisima, chairman of the bar committee, did not disclose that he had a nephew who was taking the bar examination in that year. He was merely censured and his honoraria as bar examiner were forfeited.
On September 24, 2003, the Supreme Court, per a bleary-eyed Associate Justice Jose Vitug, annulled the tests results on mercantile law after "confirmation of what could be the most widespread case of cheating in the 104-year-old bar exams".[42]
Bar Top Ten List
The Office of the Bar Confidant releases an official Bar Top Ten list together with the list of names of all successful bar examinees. The Bar Top Ten contains the names of the candidates who garnered the ten highest general averages in the bar exam for that year. The highest ranking candidate in the list is known as the bar topnotcher. The list has always been the subject of much media attention and public speculation.[43]
Making a place in the list is widely regarded as an important life achievement, an attractive professional qualification, and a necessary improvement in a lawyer's professional and social status.[43]
Famous bar top ten placers
Prominent lawyers who made the bar top ten include:[44][45][46][47][48][49][50][51][52][53]
Presidents and Vice Presidents
- Manuel A. Roxas - 1st President (3rd Philippine Republic); 1st placer (92%), 1913 Bar Exams (UP)
- Diosdado P. Macapagal - 5th President (3rd Philippine Republic); 1st placer (89.85%), 1936 Bar Exams (UST)
- Ferdinand E. Marcos - 6th President (3rd Philippine Republic); 1st placer (92.35%), 1939 Bar Exams (UP)
- Jose P. Laurel - President (2nd Philippine Republic); 2nd placer, 1915 Bar Exams (UP)
- Elpidio C. Quirino - 2nd President (3rd Philippine Republic); 2nd placer, 1915 Bar Exams (UP)
- Sergio S. Osmeña - 2nd President (Philippine Commonwealth); 2nd placer, 1903 Bar Exams (UST)
- Manuel L. Quezon - 1st President (Philippine Commonwealth); 4th placer, 1903 Bar Exams (UST)
- Carlos P. Garcia - 4th President (3rd Philippine Republic); 7th placer, 1923 Bar Exams (PLS)
- Emmanuel N. Pelaez - former Philippine Vice President; 1st placer, 1938 Bar Exams (UM)
- Arturo M. Tolentino - former Philippine Vice President; 2nd placer, 1934 Bar Exams (UP)
Curiously, each President of the Philippines who happened to be a lawyer was always a bar placer. The other Presidents (i.e., Emilio F. Aguinaldo, Ramon F. Magsaysay, Corazon C. Aquino, Fidel V. Ramos, Joseph E. Estrada and Gloria M. Arroyo) were all non-lawyers (and hence could not have been bar placers). For the 2010 presidential elections, among those who have declared their intention of seeking the highest post of the land is Gilberto Teodoro. Aside from being a Secretary of Defense (like former Presidents Magsaysay and Ramos), Secretary Teodoro (a lawyer from the University of the Philippines) placed first in the 1989 Bar Exams with a grade of 86.185%. Topnotcher Teodoro placed fourth in the elections behind incumbent President Benigno S. Aquino III (an economics major), President Joseph E. Estrada (who took up engineering) and Sen. Manuel B. Villar (a business major). A lawyer, Jejomar C. Binay (from UP), captured the vice presidency when he bested former Sen. Manuel A. Roxas II (an economist and grandson of the first bar topnotcher, President Manuel A. Roxas).
In Philippine political history, two bar topnotchers sought the presidency but failed. Vice President Pelaez (1938 Bar Topnotcher) lost the Nacionalista Party nomination to President Marcos (1939 Bar Topnotcher) for the 1965 presidential elections. Senate President Jovito Salonga (1944 Bar Topnotcher) of the Liberal Party lost to President Ramos of Lakas-NUCD in the 1992 presidential elections.[54]
Supreme Court and Court of Appeals Justices
- Jose Yulo - 6th Philippine Chief Justice; 3rd placer, 1913 Bar Exams (UP College of Law)
- Ricardo Paras - 8th Philippine Chief Justice; 2nd placer, 1913 Bar Exams (UP College of Law)
- Cesar Bengzon - 9th Philippine Chief Justice; 2nd placer, 1919 Bar Exams (UP College of Law)
- Roberto Concepcion - 10th Philippine Chief Justice; 1st placer, 1924 Bar Exams (UST Faculty of Civil Law)
- Querube Makalintal - 11th Philippine Chief Justice; 7th placer, 1933 Bar Exams (UP College of Civil Law)
- Enrique Ma. Fernando - 13th Philippine Chief Justice; 13th placer, 1938 Bar Exams (UP College of Law)
- Ramon Aquino - 15th Philippine Chief Justice; 9th placer, 1939 Bar Exams (UP College of Law)
- Claudio Teehankee - 16th Philippine Chief Justice; 1st placer, 1940 Bar Exams (Ateneo Law School)
- Pedro Yap - 17th Philippine Chief Justice; 1st placer, 1946 Bar Exams (UP College of Law)
- Andres Narvasa - 19th Philippine Chief Justice; 2nd placer, 1951 Bar Exams (UST Faculty of Civil Law)
- Artemio Panganiban - 21st Philippine Chief Justice; 6th placer, 1960 Bar Exams (FEU Institute of Law)
- Jose P. Laurel - former Philippine Supreme Court Justice; 2nd placer, 1915 Bar Exams
- J.B.L. Reyes - former Philippine Supreme Court Justice; 6th placer, 1922 Bar Exams
- Cecilia Muñoz Palma - former Philippine Supreme Court Justice; 1st placer, 1937 Bar Exams
- Ambrosio Padilla - former Philippine Supreme Court Justice; 3rd placer, 1934 Bar Exams
- Ameurfina Melencio-Herrera - former Philippine Supreme Court Justice; 1st placer, 1947 Bar Exams
- Irene Cortes - former Philippine Supreme Court Justice; 9th placer, 1948 Bar Exams
- Carolina A. Griño-Aquino - former Philippine Supreme Court Justice; 1st placer, 1950 Bar Exams
- Isagani A. Cruz - former Philippine Supreme Court Justice; 8th placer, 1951 Bar Exams
- Rafael C. Climaco - former Philippine Court of Appeals Justice; 5th placer, 1939 Bar Exams ( Ferdinand Marcos placed 1st )
- Florentino Feliciano - former Philippine Supreme Court Justice and Chair, WTO Appellate Tribunal; 6th placer, 1952 Bar Exams
- Florenz D. Regalado - former Philippine Supreme Court Justice; 1st placer, 1954 Bar Exams
- Adolfo Azcuna - Philippine Supreme Court Justice; 4th placer, 1962 Bar Exams
- Antonio Eduardo Nachura - Philippine Supreme Court Justice; 7th placer, 1967 Bar Exams
- Presbitero Velasco, Jr. - Philippine Supreme Court Justice; 6th placer, 1971 Bar Exams
- Antonio Carpio - Philippine Supreme Court Justice; 6th placer, 1975 Bar Exams
- Arturo D. Brion - Philippine Supreme Court Justice; former Philippine Court of Appeals Justice; 1st placer, 1974 Bar Exams
- Bienvenido V. Reyes - former Philippine Court of Appeals Presiding Justice; 5th placer, 1954 Bar Exams
- Salome A. Montoya - former Philippine Court of Appeals Presiding Justice; 6th placer, 1954 Bar Exams
- Alicia V. Sempio-Diy - former Philippine Court of Appeals Justice; 5th placer, 1950 Bar Exams
- Oscar M. Herrera - former Philippine Court of Appeals Justice; 8th placer, 1953 Bar Exams
- Demetrio Demetria - former Philippine Court of Appeals Justice; 2nd placer, 1964 Bar Exams
- Mario Guariña III - former Philippine Court of Appeals Justice; 2nd placer, 1967 Bar Exams
- Lucas Bersamin - Philippine Court of Appeals Justice; 9th placer, 1973 Bar Exams
- Celia Librea-Leagogo - Philippine Court of Appeals Justice; 5th placer, 1981 Bar Exams
Only eleven of the 22 jurists who rose to become Chief Justice of the Supreme Court were bar placers, starting with Jose Yulo (3rd in 1913), followed by Ricardo Paras (2nd in 1913), then by Cesar Bengzon (2nd in 1919), then by Roberto Concepcion (1st in 1924), then by Querube Makalintal (7th in 1933) then by Enrique Fernando (13th in 1938), then by Ramon Aquino (6th in 1939), then by Claudio Teehankee, Sr. (1st in 1940), then by Pedro Yap (1st in November 1946), then by Andres Narvasa (2nd in 1951) and finally by Artemio Panganiban (6th in 1960). However, the first four chief magistrates (Cayetano Arellano, Victorino Mapa, Manuel Araullo and Ramon Avancena) became lawyers (all after graduating from the UST Faculty of Civil Law) before the establishment of the Bar Exams in 1901 while the fifth head of the judiciary (Jose Abad Santos) graduated from a foreign law school and was admitted to the Philippine bar in 1911. Six Chief Justices did not place in the Bar Exams: Manuel Moran (the father of Philippine remedial law), Fred Ruiz Castro (the father of the Integrated Bar of the Philippines), Felix Makasiar, Marcelo Fernan, Hilario Davide and the incumbent Reynato Puno).
Of the candidates to become the next Chief Justice (to replace the retiring Reynato Puno) only two were bar placers: Antonio Carpio (6th in 1975) of the UP College of Law and Arturo Brion (1st in 1974) of the Ateneo Law School. Both Carpio and Brion graduated valedictorian of their respective law classes. However, neither topnotcher made it to the apex of the judicial summit, as Atenean Renato C. Corona was appointed the chief magistrate.
Senators and Representatives
- Manuel A. Roxas - former Philippine Senate President and Speaker of the House of Representatives; 1st placer, 1913 Bar Exams
- Manuel L. Quezon - former Philippine Senate President; 4th placer, 1903 Bar Exams
- Arturo M. Tolentino - former Philippine Senate President; 2nd placer, 1934 Bar Exams
- Ferdinand E. Marcos - former Philippine Senate President; 1st placer, 1939 Bar Exams
- Jovito Salonga - former Philippine Senate President; 1st placer, 1944 Bar Exams
- Neptali Gonzales - former Philippine Senate President; 9th placer, 1949 Bar Exams
- Rodolfo Ganzon - former Philippine Senator and Iloilo City Mayor; 2nd Placer, 1950 Bar Exams
- Ernesto M. Maceda - former Philippine Senate President; 10th placer, 1956 Bar Exams
- Franklin M. Drilon - former Philippine Senate President; 3rd placer, 1969 Bar Exams
- Lorenzo Sumulong - former Philippine Senator; 1st placer, 1929 Bar Exams
- Jose W. Diokno - former Philippine Senator; 1st placer, 1944 Bar Exams
- Renato V. Saguisag (Rene Saguisag) - former Philippine Senator; 6th placer, 1963 Bar Exams
- Sergio S. Osmeña - former Speaker of the House of Representatives; 2nd placer, 1903 Bar Exams
- Jose Y. Yulo - former Speaker of the House of Representatives; 3rd placer, 1913 Bar Exams
- Aguedo F. Agbayani - former Pangasinan Representative; 5th placer, 1947 Bar Exams
- Antonio Eduardo Nachura - former Samar Representative; 7th placer, 1967 Bar Exams
- Ronaldo B. Zamora - San Juan Representative; 1st placer, 1969 Bar Exams
- Prospero Nograles - Speaker of the House of Representatives; 2nd placer, 1971 Bar Exams
- Arturo D. Brion - Assemblyman, Philippine National Assembly; 1st placer, 1974 Bar Exams
- Gilberto Eduardo Gerardo C. Teodoro, Jr. - former Tarlac Representative; 1st placer, 1989 Bar Exams
- Jose P. Laurel- former Senator; 2nd Placer 1915
Of the lawyers who became President of the Senate, only the following were bar placers: Manuel Quezon (4th in 1903), Manuel Roxas (1st in 1913), Ferdinand Marcos (1st in 1939), Arturo Tolentino (2nd in 1934), Jovito Salonga (1st in 1944), Neptali Gonzales (9th in 1949), Ernesto Maceda (10th in 1956), Franklin Drilon (3rd in 1969) and Juan Ponce Enrile (11th in 1953). Of the incumbent senators with terms expiring in 2013, five are lawyers (Ateneo Law School's Alan Peter Cayetano as well as Edgardo Angara, Joker Arroyo, Francis Escudero, and Francis Pangilinan of the UP College of Law) and none of whom were previous bar placers. Curiously, Aquilino Pimentel III of the UP College of Law (who is contesting the seat occupied by Sen. Juan Miguel Zubiri) placed 1st in the 1990 Bar Exams.
On the other hand, of those who became Speaker of the House of Representatives, only the following were bar placers: Sergio Osmena, Sr. (2nd in 1903), Manuel Roxas (1st in 1913), Jose Yulo (3rd in 1913) Querube Makalintal (7th in 1933) and Prospero Nograles (2nd in 1971). Of the chamber's other officers, only Ronaldo Zamora was a former bar topnotcher (1st in 1969).
Curiously, the incumbent heads of both houses of Congress were previous bar placers: Ateneo Law School's Nograles for the lower house and UP College of Law's Ponce Enrile for the upper house. After the 2010 elections, former Rep. Nograles (who did not run for re-election) was replaced by lawyer Feliciano R. Belmonte, Jr. (from Lyceum of the Philippines) as Speaker. Sen. Enrile retained his post as Senate President.
Appointees and career service officials
- Roberto Concepcion - Member, 1986 Constitutional Commission; 1st placer, 1924 Bar Exams
- Lorenzo Sumulong - Member, 1986 Constitutional Commission; 1st placer, 1929 Bar Exams
- Arturo Tolentino - Member, Philippine Civil Code Commission; former Minister of Foreign Affairs; 2nd placer, 1934 Bar Exams
- Ambrosio Padilla - Member, 1986 Constitutional Commission; 3rd placer, 1934 Bar Exams
- Diosdado Macapagal - President, Philippine Constitutional Convention of 1971; 1st placer, 1936 Bar Exams
- Cecilia Muñoz-Palma - President, Philippine Constitutional Commission of 1986; Chairperson, Philippine Charity Sweepstakes Office; 1st placer, 1937 Bar Exams
- Jovito Salonga - former Chairman, Presidential Commission on Good Government; 1st placer, 1944 Bar Exams
- Ameurfina Melencio-Herrera - Chancellor, Philippine Judicial Academy; Chairperson, Legal Publications Committee, Supreme Court Centenary Celebrations; 1st placer, 1947 Bar Exams
- Alicia V. Sempio-Dy - Member, Philippine Civil Code Revision Committee; former Commissioner, National Commission on Women; 5th placer, 1950 Bar Exams
- Andres Narvasa - Chairman, Preparatory Commission for Constitutional Reform; 2nd placer, 1951 Bar Exams
- Gabriel Singson - former Governor of the Central Bank of the Philippines; 2nd placer, 1952 Bar Exams
- Florentino Feliciano - Chairman, Feliciano Commission investigating the Oakwood Mutiny; 6th placer, 1952 Bar Exams
- Florenz D. Regalado - Member, 1986 Constitutional Commission; 1st placer, 1954 Bar Exams
- Jose Nolledo - Delegate, 1971 Constitutional Convention & Member, 1986 Constitutional Commission; 3rd placer, 1958 Bar Exams
- Haydee Yorac - former Chairperson, Presidential Commission on Good Government; former Commissioner, Commission on Elections; 8th placer, 1962 Bar Exams
- Adolfo Azcuna - Member, 1986 Constitutional Commission; 4th placer, 1962 Bar Exams
- Joaquin G. Bernas - Member, 1986 Constitutional Commission; Member, Feliciano Commission investigating the Oakwood mutiny; 9th placer, 1962 Bar Exam
- Anacleto C. Mañgaser (var. Mangaser) - former Chairman, Reparations Commission; 1st placer, 1949 Bar Exams
- Sergio A. Apostol - Chief Presidential Legal Counsel; 7th placer, 1958 Bar Exams
- Ismael G. Khan Jr. - former Spokesperson, Philippine Supreme Court; 6th placer, 1959 Bar Exams
- Antonio Eduardo Nachura - former Solicitor General; 7th placer, 1967 Bar Exams
- Fulgencio S. Factoran, Jr. - former Executive Secretary; 9th placer, 1967 Bar Exams
- Jose Mario Buñag - former Bureau of Internal Revenue Commissioner; 2nd placer, 1968 Bar Exams
- Ronaldo B. Zamora - former Executive Secretary; 1st placer, 1969 Bar Exams
- Franklin Drilon - former Secretary of Labor and Employment; 3rd placer, 1969 Bar Exams
- Jess Dureza - Mindanao Super Region In-charge; 10th placer, 1973 Bar Exams
- Arturo D. Brion - Secretary of Labor and Employment; 1st placer, 1974 Bar Exams
- Antonio Carpio - former Chief Presidential Legal Counsel; 6th placer, 1975 Bar Exams
- Avelino Cruz, Jr. - former Secretary of National Defense; 7th placer, 1977 Bar Exams
- Simeon Marcelo - former Philippine Ombudsman; 5th placer, 1979 Bar Exams
- Manuel Antonio J. Teehankee - former Undersecretary of Justice; Ambassador to the World Trade Organization; 1st placer, 1983 Bar Exams
- Antonio M. Bernardo - former Bureau of Customs Commissioner; 2nd placer, 1988 Bar Exams
- Gilberto Eduardo Gerardo C. Teodoro, Jr. - Secretary of National Defense; 1st placer, 1989 Bar Exams
- Persida V. Rueda-Acosta - Chief Public Attorney of the Philippines; 5th placer, 1989 Bar Exams
- Ruben Carranza, Jr. - Commissioner, Presidential Commission on Good Government; 8th placer, 1990 Bar Exams
- Maria Celia H. Fernandez - former Chief, Presidential Management Staff; 1st placer, 1997 Bar Exams
- Janet T. Abuel - Regional Director, Department of Budget and Management; 1st placer, 1998 Bar Exams
- Edwin R. Enrile - former Assistant Executive Secretary, Office of the President; Deputy Executive Secretary, Office of the President; 1st placer, 1999 Bar Exams
- Rodolfo Ma. A. Ponferrada - former Assistant Chief of Staff, Office of the Vice President; 1st placer, 2001 Bar Exams
- Leila De Lima - current Secretary of Justice; former Commission on Human Rights (CHR) Chairperson; 8th placer, 1985 Bar Exams
Local officials
- Pablo P. Garcia - former Governor of Cebu; 3rd placer, 1951 Bar Exams
- Aguedo F. Agbayani - former Governor of Pangasinan; 5th placer, 1947 Bar Exams
- Isidoro E. Real, Jr. - former Governor / Congressman of Zamboanga del Sur; 7th placer, 1961 Bar Exams
- Roldan Dalman - former Governor of Zamboanga del Norte;former Presidential Assistant for Regional Concerns, Western Mindanao 6th placer, 1975 Bar Exams
- Douglas RA. Cagas - incumbent Governor / former Congressman of Davao Del Sur; 4th placer 1967 Bar Exams
Academe
- Joaquin G. Bernas - former President, Ateneo de Manila University; Dean Emeritus, Ateneo Law School; 9th placer, 1962 Bar Exam
- Jovito Salonga - former Dean, Far Eastern University Institute of Law; 1st placer, 1944 Bar Exams
- Neptali Gonzales - former Dean, Far Eastern University Institute of Law; 9th placer, 1949 Bar Exams
- Andres Narvasa - former Dean, University of Santo Tomas Faculty of Civil Law; 2nd placer, 1951 Bar Exams
- Norberto S. Gonzales - Dean, Manuel L. Quezon University School of Law; 5th placer, 1958 Bar Exams
- Custodio O. Parlade - President Emeritus, Philippine Dispute Resolution Centre; Lecturer and Bar Reviewer; 4th placer, 1959 Bar Exams
- Agustin O. Benitez - former Dean, University of the East College of Law; 1st placer, 1959 bar Exams
- Virgilio B. Jara - Dean, San Beda College of Law 5th placer, 1962 Bar Exams
- Cesar L. Villanueva - Dean, Ateneo Law School; 2nd placer, 1981 Bar Exams
- Jose Jesus G. Laurel - former Dean, Lyceum of the Philippines College of Law; 6th placer, 1981 Bar Exams
- Roy Joseph M. Rafols - former Dean, Palawan State University College of Law; 2nd placer, 1984 Bar Exams
- Pacifico N. Castro - Law Professor and Bar Reviewer; 8th placer, 1954 Bar Exams
- Manuel T. Muro - Law Professor and Bar Reviewer, former Trial Court Judge; 6th placer, 1955 Bar Exams
- Antonio H. Abad, Jr. - Law Professor and Bar Reviewer; former Dean of the FEU Institute of Law and presently Dean of the Adamson University College of Law; 10th Placer, 1963 Bar Examinations
- Roberto San Jose - Law Professor and Bar Reviewer; 1st placer, 1966 Bar Exams
- Ruben F. Balane - Law Professor and Bar Reviewer; 2nd placer, 1966 Bar Exams
- Hildegardo F. Iñigo - former Dean, Ateneo de Davao University College of Law and Bar Reviewer, 8th placer, 1966 Bar Exams
- Jacinto D. Jimenez (Jack Jimenez) - Law Professor and Bar Reviewer; 3rd placer, 1968 Bar Exams
- Arturo de Castro - Law Professor and Bar Reviewer; 3rd placer, 1970 Bar Exams
- Rene Gorospe - Law Professor and Bar Reviewer; 2nd placer, 1979 Bar Exams
- Manuel J. Laserna, Jr. - Law Professor and Bar Reviewer (Far Eastern University, Manila, 1985-2006); 3rd placer, 1984 Bar Exams (90.95%); trial lawyer; Bar leader; founder of the Las Pinas City Bar Association (2001); and managing partner of the Laserna Cueva-Mercader & Associates Law Offices (LCM Law, Las Pinas City).
- Abelardo T. Domondon - Law Professor and Bar Reviewer; 4th placer, 1985 Bar Exams, graduate of Adamson University College of Law
- Roberto A. Gana - Law Professor and Bar Reviewer; 5th placer, 1986 Bar Exams
- Jose Maria G. Hofileña - Law Professor and Bar Reviewer; 10th placer, 1987 Bar Exams
- Michael G. Aguinaldo - Law Professor; 7th placer, 1992 Bar Exams
- Anna Leah Fidelis T. Castañeda - Law Professor; 1st placer, 1993 Bar Exams
- Shirley F. Alinea UP Law (6th Place, 1996 Bar Exams) - Law Professor (UE, Lyceum, San Sebastian)
- Maria Socorro Z. Manguiat - Law Professor; 10th placer, 1993 Bar Exams
- Maria Paz Romana S. Angeles - Law Professor; 10 placer, 1994 Bar Exams
- Carla E. Santamaria-Seña - Law Professor; 5th placer, 1995 Bar Exams
- Ralph A. Sarmiento - Dean, University of St. La Salle College of Law; International Law Bar Reviewer; 10th placer, 1997 Bar Exams
- Shennan A. Sy - Law Professor; 6th placer, 1995 Bar Exams
- Arnold De Vera - Law Professor; 8th placer, 1987 Bar Exams
- Rhett Emmanuel C. Serfino - Practicing Lawyer; Professor and Bar Reviewer (MLQU, PUP, Universidad De Manila); 3rd placer, 1997 Bar Exams
- Florin T. Hilbay - Law Professor; 1st placer, 1999 Bar Exams
- Rodolfo Ma. A. Ponferrada - Professor of Law (UP and Ateneo); 1st placer, 2001 Bar Exams
- Solomon F. Lumba - Professor of Law (UP); 4th placer, 2001 Bar Exams
- Adonis V. Gabriel - Professor of Law (SBC); 8th placer, 2001 Bar Exams
- Samson S. Alcantara - Practicing Lawyer; Professor and Bar Reviewer (MLQU); Author-Philippine Labor and Social Legislation; 3rd placer, Bar Exams
- Connie Chu - Professor(Ateneo), 2nd Place, 2002 Bar Exams
- Ma. Ngina Chan-Gonzaga - Professor(Ateneo), 4th Place, 2002 Bar Exams
- Michelle Juan - Professor(Ateneo, FEU-DLSU, PLM), 4th Place, 2002 Bar Exams
- Nyerson Dexter Tito Q. Tualla - Corporate Attorney, TransCo; Civil Law Lecturer, Manuel L. Quezon University; 4th placer, 2005 Bar Exams
- Pedro Jose F. Bernardo - Professor (Ateneo, FEU-DLSU, PLP), 8th Place, 2005 Bar Exams
- Noel Neil Q. Malimban - Business Law Lecturer and Reviewer, University of the Cordilleras; 1st placer, 2006 Bar Exams
- Guillermo A. Villasor, Jr. - Former Dean, University of Negros Occidental - Recoletos School of Law; 10th placer,1979 Bar Exams
- Marforth T. Fua - Law Professor (SBC, PLP), 8th place, 2007 Bar Exams
- Teodoro Almase - Dean, University of the Visayas, 4th place
Private sector
- Manuel Montecillo - Name Partner, Siguion Reyna Montecillo & Ongsiako (oldest law firm); 1st placer, 1948 Bar Exams
- Manuel S. Abello - Founding Partner, Angara Abello Concepcion Regala & Cruz (ACCRALAW) ; 1st placer, 1958 Bar Exams
- Nelly Favis-Villafuerte - Editor, Manila Bulletin; 7th placer, 1959 Bar Exams
- Avelino V. Cruz - Founding Partner, ACCRALAW; youngest to top the bar, 1st placer, 1962 Bar Exams
- Mercedita V. Santiago-Nolledo - Corporate Secretary, Ayala Corporation; 2nd placer, 1965 Bar Exams
- Rodolfo D. Robles - General practitioner; 1st placer, 1967 Bar Exams
- Januario B. Soller Jr. - Co-founder, Soller Chain of Pawnshops; 1st placer, 1972 Bar Exams
- Jesus M. Manalastas - Name Partner, PECABAR Law Firm; 2nd placer, 1972 Bar Exams
- Victor P. Lazatin - Senior Partner, ACCRALAW; 3rd placer, 1972 Bar Exams
- Barbara Anne Migallos - Name Partner, Roco Buñag Kapunan Migallos Law Firm; Co-founder, Migallos & Luna Law Office; 3rd placer, 1979 Bar Exams
- Mario Luz Bautista - Co-founder, Poblador Bautista Reyes Law Firm; 6th placer, 1979 Bar Exams
- Arthur Lim - former National President, Integrated Bar of the Philippines; 3rd placer, 1981 Bar Exams
- Ray C. Espinosa - Partner, SyCip Salazar Hernandez & Gatmaitan; Executive Director, Philippine Long Distance Telephone Company; President and CEO, ePLDT; President and CEO, Associated Broadcasting Corporation; Vice Chairman, Philweb Corporation; 1st placer, 1982 Bar Exams
- Agerico T. Paras - Founding Partner and Managing Partner, Paras and Manlapaz Lawyers; 6th placer, 1983 Bar Exams
- Menardo L. Guevarra - Co-founder, Serapio Guevarra Medialdea Law Firm; 2nd placer, 1985 Bar Exams
- Marlon Manuel - Director, SALIGAN (non-profit legal assistance group); 5th placer, 1994 Bar Exams
- Patricia-ann T. Prodigalidad - Partner, ACCRALAW; 1st placer, 1996 Bar Exams
- Maria Celia H. Fernandez - In-house counsel, Yuchengco group of companies; 1st placer, 1997 Bar Exams
- Jose Raulito E. Paras - Partner, Andres Marcelo Padernal Guerrero & Paras; 5th placer, 1997 Bar Exams
- Eliseo M. Zuñiga Jr. - Partner, Quisumbing Torres Law Firm; 1st placer, 2000 Bar Exams
- Valerie Feria Amante- Legal Division Head, Jollibee Group of Companies; 7th placer, 2000 Bar Exams
- Rodolfo Ma. A. Ponferrada - Associate, SyCip Salazar Hernandez & Gatmaitan; 1st placer, 2001 Bar Exams
- Ma. Theresa U. Ballelos - Associate, Quisumbing Torres Law Firm; 6th placer, 2001 Bar Exams
- Arlene Maneja - Associate, Siguion Reyna Montecillo & Ongsiako; 1st placer, 2002 Bar Exams
- Aeneas Eli S. Diaz - Associate, Villaraza & Angangco; 1st placer, 2003 Bar Exams
- January A. Sanchez - Consultant, Asian Development Bank; 1st placer, 2004 Bar Exams
- Joan A. De Venecia - Associate, SyCip Salazar Hernandez & Gatmaitan; 1st placer, 2005 Bar Exams
- Noel Neil Q. Malimban - Associate, Castillo Laman Tan Pantaleon & San Jose; 1st placer, 2006 Bar Exams
- Filemon Ray L. Javier - Associate, Quisumbing Torres Law Firm; 2nd placer, 2010 Bar Exams
1st place in the Philippine Bar Examinations
Fraternities and the Bar
From Tau Kappa Phi of the FEU Institute of Law to Tau Lambda Kappa, Epsilon Sigma Lambda Phi and Beta Alpha Lambda of the UE College of Law to Mu Kappa Phi and Tri-Delta Lex of the MLQU School of Law to Lambda Rho Beta, Alpha Phi Beta and Lex Talionis of the SBC College of Law and Gamma Delta Epsilon, Suprema Lex and Aegis Juris of the UST Faculty of Civil Law, fraternities and sororities have played a significant role in the lives of law students especially at the point of taking the Philippine Bar Exams. Below is a listing of fraternities and sororities which have produced first placers in the bar exams:
Alpha Phi Beta Fraternity
- Gregorio R. Castillo (1957)
- Henry R. Villarica (1971)
- Claudio Teehankee (1940)
- Januario B. Soller Jr. (1972)
- Vicente R. Solis (1973)
- Virgilio B. Gesmundo (1977)
- Gregorio M. Batiller Jr. (1979)
- Joseph P. San Pedro (1991) - renounced
- Cesareo Antonio S. Singzon, Jr. (2010)
Beta Sigma Lambda
- Manuel G. Montecillo (1948)
Delta Lambda Sigma Sorority
- Janette Susan L. Pena (1985)
Fraternal Order of Utopia
- Cornelio C. Gison (1963)
- Arturo D. Brion (1974)
- Jayme A. Sy Jr. (1992)
Lex Leonum Fraternitas
- Reinier Paul R. Yebra (2009)
Portia Sorority
- Cecilia A. Munoz (1937)
- Amuerfina A. Melencio (1947)
- Maria Yvette O. Navarro (1988)
Scintilla Juris Fraternity
- Rafael R. Lagos (1980)
Sigma Delta Phi Sorority
- Ameurfina A. Melencio (1947)
- Patricia Ann T. Prodigalidad (1996)
Sigma Rho Fraternity
- Pedro L. Yap '39 (1946)
- Manuel G. Montecillo '39 (1948)
- Manuel G. Abello '54 GA ' 57 (1958)
- Cosme D. Rosell '75 (1978)
Theta Epsilon Sorority
- Judy A. Lardizabal (2008)
Upsilon Sigma Phi
- Ferdinand E. Marcos (1939)
- Rodolfo A. Ponferrada (2001)
Tau Gamma Phi
External links
- Supreme Court of the Philippines
- Integrated Bar of the Philippines
- Integrated Bar of the Philippines - Negros Oriental Chapter
- Chief Justice Artemio Panganiban, With Due Respect,How to pass, nay, top the bar exams
See also
- Legal education in the Philippines
- Integrated Bar of the Philippines
- Supreme Court of the Philippines
- 2010 Philippine Bar exam bombing
References
- ^ gmanews.tv, Record 6,533 to take 2008 Bar Exams - SC
- ^ Inquirer.net, First bar exam in RP held in 1901, with 13 test takers
- ^ Inquirer.net, 1,289 pass bar exams
- ^ a b Section 5, Rule 138, Revised Rules of Court.
- ^ Section 6, Rule 138, Revised Rules of Court.
- ^ Section 2, Rule 138, Revised Rules of Court.
- ^ Section 12, Rule 138, Revised Rules of Court.
- ^ Section 12, Rule 138, Revised Rules of Court.
- ^ Section 12, Rule 138, Revised Rules of Court.
- ^ Rufus Rodriguez. Slaying the Bar Exams Dragon. Rex Bookstore, 2002.
- ^ http://sc.judiciary.gov.ph/bar/announcement/index.php
- ^ a b Rufus B. Rodriguez. Slaying the Bar Exams Dragon. Rex Bookstore, 2002.
- ^ Section 14, Rule 138, Revised Rules of Court.
- ^ Section 14, Rule 138, Revised Rules of Court.
- ^ a b c d Bar Passing Percentage from 1946-2003. The Practice: Business & Leisure Magazine for Lawyers. August-September 2004 Issue.
- ^ "With Due Respect : Is the bar exam still necessary?". Inquirer.Net. 2007-04-29. Retrieved 2007-07-23.
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(help) - ^ Statistical Data of Philippine Bar Examinations, Office of the Bar Confidant, Supreme Court of the Philippines.
- ^ CHED 2009 List of Law Schools based on Bar Exam Passing Rate
- ^ Inquirer.net, With Due Respect, How Arroyo can help produce better lawyers
- ^ a b c d e f g h i j k l List of Bar Topnotchers from 1913 to 2006, Office of the Bar Confidant, Supreme Court of the Philippines.
- ^ a b c Manila Times, 12 April 2008
- ^ http://www.businessmirror.com.ph/home/life/6339-balancing-the-scales-what-its-like-to-have-two-supreme-court-justices-for-parents.html
- ^ Florenz Regalado
- ^ Inquirer.net, Regalado’s 96.7% remains unsurpassed in RP bar exams history
- ^ GMA NEWS.TV, Women outshine men in RP bar exams
- ^ http://archive.inquirer.net/view.php?db=1&story_id=60477
- ^ http://www.attyralph.com/BarTips/Stats.Bar_Trivia.html
- ^ http://en.wikipilipinas.org/index.php?title=Tecla_San_Andres-Ziga
- ^ http://www.senate.gov.ph/senators/sen_bio/enrile_bio.asp
- ^ http://www.senate.gov.ph/senators/sen_bio/enrile_bio.asp
- ^ Cruz, Miguel. "Bar Topnotchers 1970-2000". Inquirer. Inquirer. Retrieved June 12, 2003.
- ^ Business Mirror, 1 April 2008
- ^ Rufus B. Rodriguez. Legal Research. Rex Bookstore, 2002.
- ^ Section 6, Rule 138, Revised Rules of Court.
- ^ Supreme Court resolution in Bar Matter No. 1161. 2005.
- ^ Section 6, Rule 138, Revised Rules of Court.
- ^ JBL: Selected Speeches and Essays in Honor of Justice Jose B.L. Reyes, p. 57-58
- ^ Ricardo B. Teruel. Practical Lawyering in the Philippines. Revised Edition. Central Professional Books, 1999.
- ^ Section 17, Rule 138, Revised Rules of Court.
- ^ Section 19, Rule 138, Revised Rules of Court.
- ^ query.nytimes.com, AROUND THE WORLD; 12 Philippine Justices Resign in Scandal. Since the 1982 "Ericta Scandal", it was only in 2008 that the Court relaxed the fixed rules on passing grades amid the inhibitions of 5 Justices whose relatives took the exams.
- ^ sun star, Bar leakage extends exams by one Sunday
- ^ a b "Results of the Philippine Bar Exams." TV Patrol World, ABS-CBN, March 2006.
- ^ Roll of Attorneys of the Supreme Court, June 2007.
- ^ Faculty and alumni list, Ateneo School of Law, June 2007.
- ^ Faculty and alumni list, FEU Institute of Law, June 2007.
- ^ Faculty and alumni list, Lyceum of the Philippines College of Law, June 2007.
- ^ Faculty and alumni list, MLQU College of Law, June 2007.
- ^ Faculty and alumni list, San Beda College of Law, June 2007.
- ^ Faculty and alumni list, San Sebastian College-Recoletos College of Law, June 2007.
- ^ Faculty and alumni list, UE College of Law, June 2007.
- ^ Faculty and alumni list, UP College of Law, June 2007.
- ^ Faculty and alumni list, UST Faculty of Civil Law, June 2007.
- ^ http://opinion.inquirer.net/inquireropinion/columns/view/20090917-225604/Bayanis-threat-to-bolt
- ^ http://www.mb.com.ph/articles/342809/preserve-edsa