Title
Pimentel vs. Legal Education Board
Case
G.R. No. 230642
Decision Date
Nov 9, 2021
The Supreme Court of the Philippines upholds the powers of the Legal Education Board while declaring certain provisions of Republic Act No. 7662 unconstitutional, including the imposition of a minimum passing rate for law school admissions, but validates the PhiLSAT requirement and the requirement of a LL.B. or J.D. degree for admission to the LL.M. program.
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Case Digest (G.R. No. 230642)

Facts:

  • Multiple petitioners, including Oscar B. Pimentel, contested the constitutionality of provisions in Republic Act No. 7662 (RA 7662) and actions by the Legal Education Board (LEB).
  • Respondents were LEB Chair Hon. Emerson B. Aquende and member Hon. Zenaida N. Elepaño.
  • The case was consolidated with another petition by Francis Jose Lean L. Abayata against Executive Secretary Salvador Medialdea and the LEB.
  • Petitioners argued that the LEB's imposition of the Philippine Law School Admission Test (PhiLSAT) and other regulations infringed on the academic freedom of law schools and the Supreme Court's authority over legal education and the practice of law.
  • On November 9, 2021, the Supreme Court declared certain provisions of RA 7662 unconstitutional while upholding others.

Issue:

  • (Unlock)

Ruling:

  1. Invalidation of LEBMO No. 7-2016: The Court declared LEBMO No. 7-2016 unconstitutional and vacated all related LEB issuances.
  2. LEB's Jurisdiction: The Court upheld the LEB's jurisdiction over legal education.
  3. PhiLSAT Requirement: The PhiLSAT requirement was declared unconstitutional for violating academic freedom.
  4. Optional PhiLSAT: The Court's ruling rendered the PhiLSAT optional.
  5. Permanent TRO: The Court made permanent the TRO from March 12, 2019, allowing law schools to decide on the admission of conditionally admitted students.
  6. Invalidation of LEBMO Sections: The Court invalidated Sections 15, 16, and 17 of LEBMO No. 1-2011.
  7. No Cogent Reason to Amend/Reversal: The Court found no reason to amend or rev...(Unlock)

Ratio:

  • State Interest: The Court acknowledged the State's interest in improving legal education to meet global standards.
  • Reasonable Exercise of Police Power: The exercise of police power must be reasonable and should not infringe on acade...continue reading

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