G.R. No. 230642.
September 10, 2019 (Case Brief / Digest)
Title: Pimentel, et al. vs. Legal Education Board, et al.: A Disquisition on the Limits and
Ambit of State Regulation over Legal Education and the Entrenchment of Academic
Freedom
Facts:
This case stems from the consolidated petitions challenging the constitutionality of Republic
Act (R.A.) No. 7662, otherwise known as “The Legal Education Reform Act of 1993,” which
established the Legal Education Board (LEB). The act aimed to uplift the standards of legal
education in the Philippines. The LEB issued several orders, including Memorandum Order
No. 7, Series of 2016, which mandated a nationwide PhiLSAT (Philippine Law School
Admission Test). The petitions argued that the LEB’s establishment and its issuances
infringe upon the Supreme Court’s exclusive power over the practice of law and encroached
upon the academic freedom of educational institutions and the right to education of law
students. After the issuance of a Temporary Restraining Order (TRO) by the Supreme Court,
various motions and interventions were filed. Some petitioners were students whose
enrollment was affected by the PhiLSAT, while others included law schools and law
professors arguing the imposition of the PhiLSAT affected law school admissions and
curriculum autonomy.
Issues:
1. Whether or not the creation of the LEB and its power to administer a nationwide law
school admission test (PhiLSAT) violates the Supreme Court’s exclusive prerogative over the
practice of law.
2. Whether or not the LEB’s actions and the implementation of the PhiLSAT encroach upon
the institutional academic freedom of law schools.
3. Whether or not the LEB’s actions and the PhiLSAT infringe upon an individual’s right to
education.
Court’s Decision:
The Supreme Court upheld the constitutionality of R.A. No. 7662 and the creation of the
LEB but emphasized the need for the exercise of its powers to accord with the principle of
reasonableness, respecting the bounds of institutional academic freedom and individual
right to education. The Court distinguished between the regulation of legal education, which
falls under the State’s police power, and the admission to the practice of law, which remains
the Court’s exclusive domain. The Court found that the establishment of standards (such as
the PhiLSAT) for admission to law schools is within the purview of the State’s regulatory
powers to ensure quality legal education and is not an improper encroachment upon
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G.R. No. 230642. September 10, 2019 (Case Brief / Digest)
academic freedom or the Court’s prerogatives. However, such regulatory measures must
always be reasonable, not arbitrarily restrictive, and sensitively applied to foster rather than
hinder access to legal education and the profession.
Doctrine:
The doctrine established in this case reiterates the State’s power to regulate education
under its police power, emphasizing that this regulatory authority must be exercised within
reasonable bounds and must not infringe upon the Court’s exclusive jurisdiction over the
practice of law. It also underscores the importance of institutional academic freedom,
ensuring that law schools retain significant autonomy in determining their academic
policies, including admissions, curriculum development, and faculty hiring, while
conforming to minimum standards set by regulatory bodies like the LEB.
Class Notes:
1. Police Power: The State’s inherent power to regulate matters of health, safety, morals,
and general welfare of the community, including education, subject to constitutional
limitations.
2. Academic Freedom: The freedom of the institution and individual faculty members to
decide on academic matters such as the admission of students, course content,
methodology, and research focus, within the bounds of the law.
3. Article VIII, Section 5(5) of the 1987 Philippine Constitution: Establishes the Supreme
Court’s exclusive power to promulgate rules concerning the protection and enforcement of
constitutional rights, pleading, practice, and procedure in all courts, the admission to the
practice of law, the Integrated Bar, and legal assistance to the underprivileged.
Historical Background:
The context of this case reflects ongoing tensions between the judiciary’s exclusive
authority over the legal profession and the legislative and executive branches’ general
power to regulate education for the public welfare. The passage of R.A. No. 7662 and the
establishment of the LEB and the PhiLSAT were legislative responses to perceived needs for
reform and standardization in legal education amidst concerns over the quality of law
graduates and their readiness for the bar exam and legal practice. This case exemplifies the
constitutional dialogue between the branches of government over the limits of their
respective authorities in advancing legal education and the legal profession in the
Philippines.
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