G.R. No. 230642 , September 10, 2019
OSCAR B. PIMENTEL, ET AL., PETITIONERS, VS. LEGAL EDUCATION BOARD, AS REPRESENTED BY ITS CHAIRPERSON, HON. EMERSON B. AQUENDE, AND LEB MEMBER HON. ZENAIDA N. ELEPAÑO, RESPONDENTS; ATTY. ANTHONY D. BENGZON, ET AL., RESPONDENTS-IN-INTERVENTION; APRIL D. CABALLERO, ET AL., PETITIONERS-INTERVENORS; [G.R. No. 242954] FRANCIS JOSE LEAN L. ABAYATA, ET AL., PETITIONERS, VS. HON. SALVADOR MEDIALDEA, EXECUTIVE SECRETARY, AND LEGAL EDUCATION BOARD, RESPONDENTS.

FACTS

The case involves consolidated petitions challenging the validity of certain provisions of Legal Education Board (LEB) Memorandum No. 18, Series of 2017, which prescribes the new rules and regulations for admission and retention of law students. The petitioners include law students, law professors, and a law school (St. Thomas More School of Law and Business, Inc.). The respondents are the Legal Education Board and its officials. The core dispute revolves around the authority of the LEB to set admission standards for law schools, such as requiring a minimum grade in English and a minimum grade point average (GPA) for undergraduate studies, and its interplay with the constitutional rights of citizens to select a course of study and the academic freedom of educational institutions.

ISSUE

The primary legal issue is whether the LEB, in exercising the State’s power of reasonable supervision and regulation over educational institutions, can impose standardized admission requirements for law schools, and how this power balances with the intersecting constitutional rights of citizens to select a profession or course of study (subject to fair, reasonable, and equitable admission requirements) and the academic freedom enjoyed by institutions of higher learning.

RULING

Justice Lazaro-Javier, in her Concurring and Dissenting Opinion, provides a framework for balancing the intersecting constitutional rights and interests. She posits that the State has a duty to provide quality education and may set admission standards. The citizen has a right to select a profession or course of study, but this does not guarantee admission and is subject to fair, reasonable, and equitable requirements. Institutions of higher learning enjoy academic freedom, which includes determining who may be admitted to study. None of these rights is superior; the Court must balance them. The opinion emphasizes that the determination of what constitutes quality education, including setting admission standards, is best left to the political departments (like the LEB) which have the necessary expertise, as recognized in constitutional deliberations. The duty of providing quality education entails the duty of screening those who seek it. The State’s power to regulate is exercised to assure access to quality education. The opinion dissents from parts of the main decision, arguing that the presumption of validity should attach to the LEB’s regulations, and they should not be lightly set aside absent a clear factual foundation showing their unreasonableness. The regulations are seen as a valid exercise of the State’s role in ensuring the quality of legal education.