Case Digest (G.R. No. 230642)
Facts:
Oscar B. Pimentel, et al. v. Legal Education Board, G.R. Nos. 230642 and 242954, November 9, 2021, Supreme Court En Banc, Zalameda, J., writing for the Court.Petitioners in the consolidated proceedings comprised law-school applicants and students, individual law-school stakeholders, and intervening petitioners including St. Thomas More School of Law and Business, Inc. and the Philippine Association of Law Schools (PALS); respondents were the Legal Education Board (LEB) (represented by its Chair Emerson B. Aquende and members) and Executive Secretary Salvador Medialdea, with several attorneys appearing as respondents-in-intervention. The matters arose from challenges to the constitutionality and validity of provisions of Republic Act No. 7662 (the Legal Education Reform Act of 1993) and numerous LEB issuances—most centrally LEB Memorandum Order No. 7-2016 (LEBMO No. 7‑2016) creating the Philippine Law School Admission Test (PhiLSAT) and related memoranda and circulars (e.g., LEBMC No. 18‑2018, LEBMC No. 6‑2017, LEBMO No. 1‑2011).
On September 10, 2019 the Court En Banc (Reyes, J., ponente) issued a decision in these consolidated cases partly granting relief: it upheld the LEB’s jurisdiction over legal education, struck down several statutory and regulatory provisions as unconstitutional or ultra vires (including Section 9 of LEBMO No. 7‑2016 insofar as it made passing PhiLSAT an absolute prerequisite for admission), and made permanent a TRO enjoining implementation of LEBMC No. 18‑2018. After that decision, PALS filed a request for clarification (docketed A.M. No. 20‑03‑04‑SC) and later a formal Petition‑in‑Intervention; respondents and petitioners filed motions for reconsideration of the September 10, 2019 Decision.
The Court treated PALS’s letter as a motion for leave to intervene, consolidated the matter, entertained the parties’ motions for reconsideration, and issued the instant En Banc Resolution resolving those motions and PALS’s intervention. The controversy presented constitutional questions ...(Pro-only)
Issues:
- Is there a cogent reason to declare the entirety of RA 7662 and LEBMO No. 7‑2016 unconstitutional rather than invalidating only parts of them?
- Did the Court err in upholding the jurisdiction of the Legal Education Board over legal education?
- Did the Court err in holding that requiring passage of the PhiLSAT (or a valid certificate of exemption within two years) and a 55% passing score unconstitutionally infringes law schools’ academic freedom to decide who to admit?
- Did the Court’s ruling render the PhiLSAT optional?
- Did the Court err in making permanent the TRO issued on March 12, 2019 and in leaving regularization of conditionally admitted students to law schools’ discretion?
- Did the Court err in invalidating Sections 15, 16, and 17 of LEBMO No. 1‑2011?
- Is there reason to reverse the Court’s declaration that several LEB issuances prescribing minimum qualifications and classifications for faculty, deans, and graduate‑school deans violate institutional academic freedom?
- Are LEBMO No. 22‑2019, LEBMC No. 6‑2017, and LEB Resolution No. 2012‑...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)