G.R. No. 230642 and G.R. No. 242954, 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; ATTYS. ANTHONY D. BENGZON, ET AL., RESPONDENTS-IN-INTERVENTION; APRIL D. CABALLERO, ET AL., PETITIONERS-INTERVENORS; FRANCIS JOSE LEAN L. ABAYATA, ET AL., PETITIONERS, VS. HON. SALVADOR MEDIALDEA, EXECUTIVE SECRETARY, AND LEGAL EDUCATION BOARD, HEREIN REPRESENTED BY ITS CHAIRPERSON, EMERSON B. AQUENDE, RESPONDENTS.

FACTS

These consolidated petitions assail the constitutionality of Republic Act (R.A.) No. 7662 (the Legal Education Reform Act of 1993), which created the Legal Education Board (LEB), and the LEB issuances establishing and implementing the Philippine Law School Admission Test (PhiLSAT). Petitioners, including law students, law school deans, professors, and other stakeholders, argue that R.A. No. 7662 encroaches upon the Supreme Court’s exclusive rule-making power concerning the practice of law, violates institutional academic freedom, and infringes upon a law school aspirant’s right to education. The law was enacted to uplift legal education standards, prepare law students for the legal profession, and improve bar examination performance. It grants the LEB powers to administer the legal education system, supervise law schools, set accreditation standards, prescribe minimum admission standards and basic curricula, establish law practice internship, and adopt a system of continuing legal education. The Supreme Court’s Committee on Legal Education and Bar Matters (CLEBM) had previously noted in 2001 that certain provisions of R.A. No. 7662 appeared to encroach upon the Court’s constitutional powers over the practice of law and the Integrated Bar of the Philippines.

ISSUE

Whether R.A. No. 7662 and the LEB issuances implementing the PhiLSAT are unconstitutional for encroaching upon the Supreme Court’s exclusive rule-making power over the practice of law, violating academic freedom, and infringing upon the right to education.

RULING

The Supreme Court declared R.A. No. 7662 UNCONSTITUTIONAL for encroaching upon the Court’s exclusive power to regulate the practice of law. The Court held that the power to regulate the practice of law, which includes the power to regulate legal education in preparation for such practice, is exclusively vested in the Supreme Court under Section 5(5), Article VIII of the 1987 Constitution. The law’s provisions granting the LEB powers to prescribe minimum standards for law admission, basic curricula aligned to bar admission requirements, law practice internship as a bar requirement, and a system of continuing legal education for practicing lawyers directly intrude upon this exclusive judicial domain. Consequently, the LEB and all its issuances, including those establishing the PhiLSAT, have no legal basis and are void. The Court emphasized that while the State has a legitimate interest in improving legal education, it must do so in a manner that respects the constitutional separation of powers and the Court’s exclusive authority over all aspects of the practice of law. The petitions were granted.