History of the Philippine BAR Examination
Rogelio G. Balo Ph.D.
The Origin of the BAR Examination
*Of course, the term “BAR” is not an acronym.
*When people go to court, there is a barrier between the
general public and the court, judge, and magistrate as well as the tables for the litigants/parties and their attorneys
positioned in front of the judge’s bench but within the area that is beyond
*that* barrier or “bar” If you will. *
Unless you are a party or a litigant in the case that is before the court at that particular time, a lay person cannot cross that barrier or “bar” that separates the judge/court/magistrate from everyone else.
Hence, that is an area that is part of or across the “bar”.
As a judge or properly licensed attorney, solicitor, barrister you are now officers of the court, who all had
similar required criteria that got them “into the bar” and who have similar
rules governing their conduct and anyone else who is a “member of the bar”.
Thus, they are all allowed to ““pass through the bar” of courts or the
“barriers” however you prefer…
*Rui Santos
In the Philippines, in order to practice the law profession,
law graduates must pass the BAR exam to become members of the Philippine BAR.
*First Philippine Bar Exam
The first Philippine Bar Exams was conducted in 1901 with
only 13 examinees.
The third Philippine Bar Exam took place in 1903 but the
results were released in 1905. José I.
Quintos obtained the highest rating of 96.33%, Sergio Osmeña, Sr. was second with 95.66%, F. Salas was third with 94.5% and Manuel L. Quezon fourth with 87.83%.
After the 1903 exam,
rankings were again avoided until the 1913 exam, which meant that every other
year from the inaugural 1901 examination to 1912 no scores were given other
than pass or fail.
For the period from 1913 to 2019, schools which have
produced 1st placers in the BAR exam
are as follows:
University of the Philippines
College of Law – 49 Ateneo Manila Law School – 23
San Beda College of Law – 8 Philippine
Law School – 5
University of Santo Tomas Faculty
of Civil Law – 4 FEU Institute of Law – 4
University of Manila College of
Law – 4 U of the Cordilleras – 2
University of San Carlos School
of Law – 1 UE College of Law – 1
USLS (Bacolod ) – 1 UST –Legazpi – 1
Manuel L. Quezon University – 1 San
Beda College Alabang - 2
San Sebastian College - Recoletos – 1 University of San Agustin Iloilo - 1
Holy Name University (formerly
Divine Word College of Tagbilaran) College of Law – 1
Manila Law College Foundation
(formerly Escuela de Derecho de Manila) – 1
Two (2) bar examinees topped the bar exams without
officially graduating from any Philippine law school
The Legends of the
Philippine BAR
*Claro M. Recto
Recto was born on February 8, 1890, at Tiaong, Tayabas (now
Quezon Province).
He graduated with a Bachelor of Arts degree from Ateneo de
Manila where his grades were all perfect (1.0),
except only for one 1.3. He was
conferred by Ateneo with Maxima Cum Laude
honors (highest honors conferred by Ateneo).
He took the Bar Exams in 1913 while he was still in his
senior year in law school at the University of Santo Tomas – and FLUNKED.
He finished his law degree in 1913, Class Valedictorian, University of Santo Tomas.
The 1913 Bar Exams marked the first time that the test
questions in Civil Procedure were in English, a new language in which Recto
could not express himself very well. Justice Fischer, the examiner in Civil
Procedure, also noted that Recto’s handwriting was very difficult to understand and gave Recto a grade of 41 which automatically disqualified him.
Recto took the Bar Exams again in 1914 and passed. The No. 1
topnotcher of the 1914 Bar exams was Manuel
Goyena.
After passing, Recto wrote two books on Civil Procedure.
When Recto studied in Ateneo and UST, the medium of
instruction was Spanish. Manuel Roxas,
on the other hand, UP’s Class Valedictorian who topped the 1913 Bar Exams was a
product of the US public school system and had spent a year in Hong Kong to
better equip himself with American English before taking the Bar.
*Ferdinand E. Marcos
On September 20, 1935, Ilocos Norte politician Julio
Nalundasan was at home celebrating that day’s Congressional election victory
over Mariano Marcos when he was shot and killed by a .22-caliber bullet alleged
fired by the 18-year-old son of the losing candidate, Marcos.
On December 13, 1938, Marcos was arrested for Nalundasan’s
murder, but he successfully petitioned for release on bail, allowing him to complete his law degree from the University of the
Philippines.
In 1939, Marcos was found guilty and sentenced to a minimum
of 10 years in prison.
While in jail, Marcos spent six months writing his own
830-page appeal while reviewing for the Bar Exams at the same time. Marcos
posted bail to take the 1939 Bar Exams and passed with scores so high he was
suspected of cheating.
Legends say that his
unofficial Grade was 98.5 and so he was summoned to appear before the Supreme
Court en banc for an oral re-examination, after which his official grade was
released as 92.35.
Marcos is the only Bar
candidate who was called by the Supreme Court for an oral re-examination.
In 1940, Marcos orally argued his own case in front of
Supreme Court Justice Jose P. Laurel and on October 22, 1940, he was acquitted
of the charge of murder and forthwith liberated from imprisonment. The next
day, he returned to the Supreme Court where he was administered his oath as a
lawyer.
*Jose W. Diokno
J.W Diokno was former Senator of the Philippines; 1st placer, 1945 bar exams. Mr. Diokno, who tied
for Number 1 with former Senate President Jovito
Salonga in the 1945 Bar Exams, would have graduated from the University of
Santo Tomas had not World War II supervened.
Diokno earned his bachelor’s degree in Commerce Summa Cum Laude in 1940 at De La Salle
College (now De La Salle University). He took the CPA Board Exam in 1940 while
he was in his second year in law school and placed No. 1.
In 1944, he petitioned the Supreme Court to take the Bar
Exams without a law degree.
The Supreme Court granted his petition, and he took the Bar
Exams in 1944 and tied with the Class Valedictorian of U.P. for the 1st Place
with a grade of 95.3.
Diokno is the only one who placed 1st in both the CPA board exams & the Bar Exams.
Mr. Diokno's
success in the bar exams is further underscored by the fact that he was also
under-age and that he also placed number 1 in the 1940 CPA Board exams which he
took while in law school, summa cum laude
after graduating from then De La Salle College at the age of 17. This double
number 1 feat may never be paralleled.
*Carolina C. Griño-Aquino
Atty. Grino Aquino was a former Associate Justice of the Supreme Court
and 1st placer in the 1950 bar exams. Ms. Aquino (who later became the wife of
Mr. Ramon Aquino, 6th placer in 1939 Bar Exams) was a special student of UP
College of Law, where she finished her last two years of law school having
taken her first two years of law school at the Colegio de San Agustin in
Iloilo. Ms. Aquino was advised to take her last two years of law school in UP
by Colegio de San Agustin Law Dean Felipe Ysmael. Coincidentally, Mr. Ysmael (a
UP Law graduate himself) placed number 1 in the 1917 Bar Exams. Since Ms.
Aquino only took her last two years of law at UP, she can't be certified as an
official UP law graduate. Both spouses Aquino (in addition to being
topnotchers) also served as Justices of the Supreme Court.
*Claudio Teehankee
Being not a guarantee for topping the bar, academic
excellence in law school is a good indicator of an examinee's fortune in the
bar exams. Claudio Teehankee, Ateneo
Law School's only summa cum laude
graduate, , placed number one (1) in the 1940 Bar Exams. It is worth noting that
Teehankee's son, Manuel Antonio,
followed in his footsteps by graduating at the top of his Ateneo Law School
class (albeit, not as summa cum laude) and placing first in the 1983 bar exams.
Claudio's nephew, Enrique (a cum
laude graduate from the UP College of Law), also placed number one in the 1976
bar exams. Claudio eventually became
Supreme Court Chief Justice, Manuel Antonio was formerly Department of
Justice Undersecretary and Ambassador and Permanent Representative to the World
Trade Organization in Geneva, Switzerland while Enrique is a successful private practitioner.
This father-son-nephew feat has yet to (and, perhaps, may
never) be paralleled in the annals of the Philippine Bar.
Honor Graduates of Top Philippine Law Schools
The UST Faculty of Civil Law's sole summa cum laude graduate, Roberto
B. Concepcion, placed 1st in the 1924 Bar Exams. He later served
as Chief Justice of the Supreme Court.
The San Beda College of Law's sole magna cum laude graduate, Florenz Regalado, ranked 1st in the
1954 Bar exams with a mark of 96.70%. The record is the highest average in the
Philippine Bar Examinations, to date. Regalado later served as an Associate
Justice of the Supreme Court.
The UP College of Law (which has yet to produce a summa cum laude graduate) had 5 of its 17
magna cum laude graduates (the College of Law first conferred the honor to Rafael Dinglasan in 1925 and, to date,
last conferred the same honor to Dionne
Marie Sanchez in 2007) placed number 1 in their respective bar exams: Rafael Dinglasan in 1925, Lorenzo Sumulong in 1929, Deogracias Eufemio in 1962, Roberto San Jose in 1966 and Ronaldo Zamora in 1969.
Philippine BAR Highest Grade of All Time:
1st - 96.7% in the 1954 Bar Exams by Florenz Regalado of
San Beda College
2nd - 95.95% in the 1954 Bar Exams by Renato L. de la Fuente of San Beda College
3rd - 95.85%
in the 1949 Bar Exams by Anacleto C. Mañgaser of the Philippine
Law School (PLS)
4th - 95.5 % Manuel G. Montecillo of Far Eastern University in the 1948 Bar Exams & Antonio Quintos of Ateneo de Manila University in the 1954 Bar Exams
5th - 95.3% 1944 Bar Exams held by Jovito R. Salonga of UP and Jose W.
Diokno, who did not finish his law studies.
Bar (1st Placers) to become Presidents of the Philippines:
Manuel A. Roxas (University of the Philippines), 1913 Bar
Exams with a grade of 92.
Diosdado P. Macapagal (University of Sto. Tomas) , 1936 with
a grade of 89.85
Ferdinand E. Marcos of the University of the Philippines,
1939 with a grade of 92.35
Other Bar Placers to become Presidents of the Philippines:
Sergio S. Osmeña (University of Santo Tomas), 2nd Place –
1903 Bar Exams
Manuel L. Quezon, (University of Santo Tomas), 4th Place –
1903 Bar Exams
Elpidio R. Quirino (University of the Philippines), 2nd
Place – 1915 Bar Exams
Carlos P. Garcia (Philippine Law School), 6th Place – 1923
Bar
First Female Lawyers to Top the BAR:
Tecla San Andres Ziga and Cecilia Munoz Palma
Tecla San Andres-Ziga
of the University of the Philippines is the first woman to place No. 1 in the
Bar Exams of 1930 with a grade of 89.4.
She served as Senator of the Republic of the Philippines from 1963 to 1969.
Cecilia Munoz-Palma
of the University of the Philippines became the 2nd woman to place No. 1 in the
Bar Exams in 1937 with a grade of 92.6. She later became the 1st woman Supreme
Court Justice in 1973 and the 1st female President of a constitutional
commission in 1986.
*Wikipedia
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