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considering his possession as peace officer by the

higher authority to patrol the place where robbery are frequent.
Sharing tips from my Criminal Law Professor Atty. Ruben C. The one responsible for this is the Municipal Mayor who order
Talampas, Jr. without warrant of arrest and the act of the patrolman are in good
faith believing to be a robbery entering a house. So the proper
party liable is the Municipal Mayor.
By: Atty. Ruben C. Talampas, Jr.
Question No. 17 AA was the owner of a jeepney for hire. When
his driver was hospitalized, he hired BB as driver on a temporary
The then Chairperson of the Committee on Bar Examinations,
basis and entrusted to him the vehicle for transporting passengers
Madame Justice Ameurfina Melencio-Hererra, submitted a report to
from Quiapo to Baclaran with a compensation of P30.00 a day. BB
the Philippine Supreme Court her observations on the 1980 bar
never returned the vehicle and after search the vehicle was found in
Tarnate, Cavite, about to be sold. BB was charged with Qualified
According to her several examinees have made very unsatisfactory Theft and was convicted. Appealing the judgment of conviction,
showing to such an extent that there is one who obtained a grade as defense counsel contends that BB may have committed Estafa but
low as 7% another obtained a grade of 11%; still some others not Qualified Theft on the theory that the possession of the vehicle
obtained grades of 12%; 16%; 17%; 18%; 19%; 20%; 21%; 24%; 25%; was obtained with the consent of AA the owner, and therefore,
26%; 27%; 31%; 34%; etc. there was no illegal taking. Decide the case.

She pointed out the general weakness of the bar examinees. She Answer The defense counsel of the accused contention in
said: The reason for this high mortality rate, may be attributed to untenable assuming now that there is no illegal taking of the jeep
several factors among them in the opinion of the undersigned, may from AA. The owner but BB a temporary driver hired by AA
be due mainly to the following: . . . inadequate command of the failure to return the jeep such vehicle as now ready to be sold by
English language. BB have an intent to gain is theft cases as an element.

She further emphasized: The examinees inhabiting the lowermost Our aim, of course, is not to ridicule and immortalize these
rungs of the grading scale manifested not alone an appalling lack of Bar answers. Our aim is to remedy, correct, and supplement the
knowledge of the fundamental principles involved in the examination aforesaid deficiencies for future bar takers so that they would not
questions but also an inability to logically string their thoughts suffer the same fate.
together compounded by an almost incredible deficiency in language
By far the most important tool that the bar candidate could equip
himself with which to tackle the examination that is inherently
It was less than 35 years ago but still her remarks seem to be true at personal to him is command of written English. The examinee who
present. has a fairly good command of English, assuming that he is prepared
in all other matters, stands definitely with a much better chance of
The following are actual questions and answers of some examinees passing.
which demonstrate their lack of knowledge of the fundamental legal
principles and inadequate command of the English language: Not all the BAR tips I will be presenting here are mine. I
believe they are the collective ideas of past bar examinees, bar
Question No. 6(b) An accused was found guilty of double murder topnotchers, bar lecturers and law professors who want to share
and was meted out two sentences of reclusion perpetua. How would their experiences and have the desire and concern to help future
the accused serve the sentences? bar takers. I will try though to present these in a more
comprehensible and effective way.
Answer Both penalties must be served by the accused, and he
was electrocuted and died then it washes out the remaining A bar examinees answer should be a total package. Meaning, it
sentence to served by the accused. contains all the necessary ingredients. This is when the 4Ls come
in: law, language, logic, and layout. His answer should be legible
Question No. 11. Patrolman Cruz, acting under orders of the and neat without the irritating erasures observing the proper
Municipal Mayor, Who wanted to put a stop to the frequent margin and space between paragraphs with correct composition,
occurrence of robbery in Sitio Masukal, patrolled the place. At about grammar and spelling coupled of course of the knowledge of the
midnight, seeing three persons acting suspiciously in front of an law principles and its application to the given set of facts
uninhabited house and entering the same, he arrested them without responsive to the issue or question at hand.
warrant and took them to the municipal building where they were
detained in jail for about five hours before they were The examiner will be looking and expecting for the following from
released. Patrolman Cruz was accused of arbitrary detention. If you your answer:
were the Judge, would you convict him of the crime charged?
1. Proper understanding and appreciation of the facts, or result, such conclusion should clearly appear in your answer and
particularly of the components or details that can be should be stated concisely and without equivocation.
material in resolving the given problem;
An answer that consists entirely of mere conclusions unsupported
2. Appreciation of the applicable laws that may come into by any statements or discussion of the rules or reasoning upon
play; which it is based is entitled to little credit. Clarity and conciseness
are important, but make your answer complete. Do not volunteer
3. Recognition of the issues posed; irrelevant or immaterial information.

4. Resolution of the issues through the analysis and ARTICULATION

application of the law to the given facts; and
Articulation is expressive of the following basic fundamentals: good
5. Presentation and articulation of answer. language, impressive presentation, logical reasoning and substantial
background knowledge of law and procedure. Impressive answers
In essence, your answer should clearly indicate:
showing the candidates reasoning faculty is what the examiners
want to read in your examination notebooks.
1. the relevant facts;
Your answer should demonstrate your ability to analyze the facts
2. the applicable law;
presented by the question, to select the material from the
3. your analysis; and immaterial facts, and to discern the points upon which the question
turns. It should show your knowledge and understanding of the
4. your conclusion. pertinent principles and theories of law involved and their
qualifications and limitations. It should demonstrate your ability to
To expound it further, a Bar examinees answer should clearly apply the law to the given facts, and to reason logically in a lawyer
demonstrate: like manner to a sound conclusion from the given premises.

IDENTIFICATION OF THE PROBLEM You must also be aware that the Bar questions are not all case or
situationer problems. There are other types of Bar essay questions
Your answer should demonstrate your ability to identify correctly
you ought to know so you will be able to prepare and answer them
the problem(s) and issue(s) of law presented in the question. Your
properly in case you encounter one. The usual types of Bar essay
answer should demonstrate your ability to articulate and classify the
question are enumerated below:
problem presented, that is, to state it in a lawyer-like fashion and to
place it in its proper category or categories of doctrine. 1. Enumeration;

KNOWLEDGE OF THE LAW 2. Distinction;

Your answer should demonstrate your knowledge of legal principles 3. Definition;

and your ability to repeat them accurately on the examination as
they relate to the problem presented by the question. You should 4. Reason behind the law/concept/principle; and
state concisely the principle(s) and rule(s) governing the issue(s)
presented by the question. 5. Case Problem.


Your answer should reveal your capacity to reason logically by This type comprises an average of 80 90 percent of the questions
applying the appropriate rule or principle to the operative facts of in every subject, hence, it is imperative that you are well-versed in
the question as a step in reaching your conclusion. This involves answering the same.
making the correct preliminary determination as to which facts in
Given that you know already the law; that you know how to apply it
the question are legally important and which, if any, are irrelevant.
to the set of facts; that you write legibly enough; left you with one
The line of reasoning that you adopt should be clear and consistent problem that is how are you going to present or articulate it in an
without gaps or digressions. This is the most important element in impressive manner.
your answer and, therefore, carries the most weight in the grading
A ready outline or structure of your answer will tremendously help
you to answer faster without missing an important part. By constant
CONCLUSION practice in answering this type of question with the
outline/structure in your mind, you will be amazed how it easy for
You should address yourself to the task that the question asks you to you to start outright and tackle the question and come up with an
perform. For example, if the question calls for a specific conclusion impressive answer.
Below is the suggested outline/structure of your answer for a ANSWERING IN THE NEGATIVE
case/situationer problem question:
1. The decision is not in accord with law and jurisprudence.
1st Paragraph Positive/Negative/Qualified Answer
2. The decision is erroneous.
2nd Paragraph Applicable Law/Jurisprudence
3. The contention is totally misplaced.
3rd Paragraph Correlation of the Law/Jurisprudence with the
Facts of the Case 4. The doctrine of.. does not apply in this case.

4th Paragraph Conclusion (this may be part of the 5. The petition is not meritorious.
3rd Paragraph)
6. The evidence presented deserves scant consideration.
Okay, you already have an outline but isnt it boring for the
7. The contention has no legal basis.
examiner to read in your answers the same words or phrase at the
beginning of your paragraphs? For example you will use these words
8. The argument is bereft of merit.
in every answer: the contention is untenable; the law provides;
therefore. The examiner will spot this and might not be impressed to 9. The petition is devoid of merit.
you at all which will result to a lesser points.
You will agree that the hardest thing to do is to start. We want that Accused reliance on the (i.e. doctrine of) is inappropriate.
the first sentences or paragraph we will write will impress the
examiner and more often we cannot find the right words to start. 11. It is a futile gesture on the part of the respondent to
Would it be easier if just like the outline you have already a pool of invoke the rule on
words waiting to be used?
12. The theory/argument has no ground to stand upon.
Knowing First Liners or introductory words will greatly help you to
quickly and smoothly string your thoughts and effectively convey 13. The contention has no leg with which to stand on.
your answers. The following first liners or introductory words can
14. The position of the petitioner runs counter with the
be used interchangeably to begin every paragraph of your outlined
doctrine of
15. The case will not prosper.
The following Useful Introductory Lines are mostly taken from the
article of Atty. Rey C. Tatad, Jr. with the same title. 16. The case is not tenable.

ANSWERING IN THE POSITIVE 17. The act of the accused in is of no moment.

1. The petition is meritorious. 18. The assertion lacks substance.

2. The contention has legal basis. 19. The (i.e. respondent) cannot rely on (i.e. mere alibis) to aid
his cause.
3. The case will prosper.
20. The court cannot countenance the (i.e. inconsistent
4. The argument is proper.
postures of the petitioner)
5. The provision is perfectly applicable.
21. The testimony that, cannot be given credence.
6. The action is tenable.
22. The evidence presented has no probative value.
7. The motion should be granted.
23. The allegation is belied by the fact that
8. The Judge is correct.
24. To put it otherwise would be to render the law on
9. The petition is impressed with merit. _____________

10. Yes. It is a (i.e. patent violation) of the useless/futile.

11. There is merit in the petition. 25. The actuations of the accused in (i.e. fleeing and hiding)
negates (i.e.
12. The petitioners contention is sustainable.
26. While it is true that _______________ is a (i.e. 3. The question requires a qualified answer. If
constitutional guaranteed right
4. I will qualify. If
of a person), it does not, however mean
5. On the assumption that
27. It is not correct to say that
6. My answer must be qualified.
28. It is not proper to state that
29. It is not accurate to conclude outright that
1. No less than the (i.e. 1987 Constitution) provides for the
30. A contrary conclusion would erode the rule that provides
in part that 2. The (i.e. Rules of Court) substantially provides in part
31. To sustain the contention would be to render the law on
____________ 3. Under the broad principles of (i.e. due process clause)

nugatory. 4. Under the all-encompassing doctrine of (i.e.

incontestability clause)
32. It would be absurd and incongruous to sustain the
argument that 5. Under the law

33. It is not enough that 6. According to the (i.e. Family Code)

34. The fact that is immaterial since 7. The law is explicit on the matter.

35. The fact that is irrelevant since 8. The law explicitly expresses in part that

36. In itself, mere is not sufficient (i.e. to warrant 9. By express provision of law,
10. By operation of law
37. The petitioner cannot give any additional meaning to the
11. As a matter of law
clear and plain
12. Worth remembering is the rule on _______________
language of the law.
which provides in part that
38. The Supreme Court, in several cases, has struck down the
13. Decisive on the matter is the pertinent provision of the
(i.e. defense of alibi)
(i.e. Law on
39. The attendant circumstances of the case are contrary to
the petitioners
14. The law prescribes certain rules on
15. By legislative fiat
40. The evidence does not support the theory of the
41. There is no cogent reason to disturb the ruling of the (i.e.
1. The Supreme Court in one case, had the occasion to rule
Court of Appeals)
42. The claim for (i.e. moral damages) must necessarily fail.
2. In a long-line of cases decided by the Supreme Court, it has
always been
(consistently) held that
(But if the facts are complete in itself, do not attempt to add facts or
assume anything.)
3. In a litany of cases decided by the Supreme Court,
1. We must distinguish. If (or As far as the __________ is
4. In a long-string of cases decided by the highest court of
the land,
2. It depends. If(or As far as the __________ is concerned)
5. According to several cases decided by the Supreme 2. Immortal is the rule that
3. Well settled is the rule
6. In a series of cases decided by the Supreme Court,
4. Well entrenched is the principle that..
* Do not use the words series, litany or long-line if there is only one
5. Elementary is the rule that..
decision/jurisprudence for that topic.
6. The cardinal rule in (i.e. labor law) is that
7. In one case decided by the highest court of the land, it was
held that 7. It is a familiar canon in (i.e. political law) that

8. In one case, the Supreme Court ruled that 8. By well settled public law

9. It has been said that 9. Basic is the rule in (i.e. Criminal Law)

10. In a recent case, the Supreme Court has laid to rest the 10. It is an elementary principle in
issue of whether or not
11. It is a fundamental doctrine in
11. It is well settled in this jurisdiction
12. Well accepted is the rule that
12. It is well settled in this country
13. It is axiomatic in (i.e. Civil Law) that
13. The Supreme Court has steadfastly adhered to the
14. Enshrined in the 1987 Constitution is the rule that (i.e. no
doctrine which states
person shall be deprived of life, liberty or property without
that due process of law)

14. In a case with similar facts, the Supreme Court ruled that 15. Consonant with the rule on

15. In several notable Supreme Court decisions, the highest 16. It is a recognized doctrine in (i.e. Civil law) that
court declared that
17. It is a basic tenet in (i.e. Commercial Law)
16. The Supreme Court has often stressed that
18. Consistent with current jurisprudence
17. In the landmark case of _____________, (if the case is so
19. It is a legal presumption, born of wisdom and experience,
famous) the
Supreme Court laid down the doctrine which substantially provides
20. It is an oft-repeated rule that
21. The Philippines adhere to the principle of
18. In the leading case of
19. As enunciated by the Supreme Court in one case,
(correlating the facts with the law/jurisprudence)
20. The court has repeatedly ruled
1. Applying the said law/doctrine in the instant case,
21. A case in point is a case already decided by no other than
the highest court of the land, where the Supreme Court
2. From the facts given, noteworthy is the
held that
3. From the facts of the case, it is readily observable that
22. There is likewise an array of cases in this jurisdiction where
the Supreme Court has consistently declared that 4. In the instant case, it may be observed that

23. Deeply rooted is the jurisprudence which provides that 5. It is crystal clear from the facts presented that (i.e. the
crime of treason) is present (or was committed).
24. In one case, the Supreme Court was emphatic when it
ruled that. 6. In the present case, it is immediately noticeable that the
element of
__________ is wanting (or lacking).
1. It is hornbook doctrine in (i.e. Civil Law) that
7. Under the circumstances, the proper remedy would be 9. Consequently,

8. The case obtaining indicates a case of (i.e. B.P. 22) 10. As a necessary consequence

9. It logically follows 11. The logical implication is that

10. It goes without saying 12. At any rate,

11. Even assuming arguendo, for the sake of argument that 13. In view of the foregoing,

12. The situation in the case at hand 14. As an inevitable conclusion,

13. The situation presented evinces a case of 15. In the light of the circumstances,

14. The facts sufficiently indicated 16. Undoubtedly,

15. In the given facts, it is immediately apparent that 17. Indubitably,

16. It is evident that 18. Clearly, the case at hand falls squarely within the purview
17. In the same token
19. Verily, he/she has committed
18. Under the facts stated in the problem,
20. For this/these reason/s, it is unavoidable to conclude
19. In the case under consideration, that

20. Worth stressing is the fact that 21. Based on the facts obtaining,

21. Worth emphasizing is the fact that 22. In this light,

22. The facts would reveal that 23. This being the case

23. A careful perusal of the facts of the case would reveal 24. Clearly therefore, applying the aforecited ruling in the case
that at hand,

24. A careful scrutiny of the actuations of the accused would 25. In light of the foregoing, it is beyond cavil (doubt) that,
reveal that
26. There is no doubt that
25. A careful reading of the (i.e. Deed of Absolute Sale) would
reveal that 27. To the unprejudiced mind, the actuations of the three,
when analyzed and taken together, leads to no other
26. A cursory examination of the conclusion except that (i.e. conspiracy

CONCLUDING WORDS among them existed)

1. From the gamut of evidence on hand, it can be 28. Inescapably, therefore,

gathered/deduced that,
29. All things considered,
2. Taken all together,
30. It follows therefore that
3. Finally,
31. As a logical result
4. Hence,
32. In sum,..
5. Therefore,
33. In view of the fact that,
6. From the foregoing, it can be deduced that there is really
(i.e. a violation of) 34. All told,

7. From the foregoing, it is now safe to conclude that. 35. Given the prevailing facts

8. Lastly, 36. Having stated the foregoing premises,

37. One final point, 2.

38. Accordingly, 3.

Using the outline and the first liners above, make a format or If you cannot enumerate all, write it in paragraph form so that it
model of your answer and use what you deem is applicable in a would not easily be noticeable that you missed something.
given question. You may make your own models as many as you
want but it is suggested to have at least 10 models. Here are some 1. In capsule form, the following are the elements of the
examples (taken from my 2007 Bar Tips to NEU and INC Bar crime of _______
2. In a nutshell, the following are the elements of the crime
No/Yes. He can/cannot.., of _________

The law provides that/The Supreme Court has held in a line of 3. The following elements are generally considered in the
cases determination of

In the case at bar.. the presence of (i.e. employer-employee relationship)

Hence.. 4. Among the (i.e. defenses/remedies) available to (i.e. Mr. X)

as provided for by/in the (i.e. Civil Code) are:
Xs claim is not meritorious, hence the case should be decided
against him (1)

According to the law/The Supreme Court, in many cases, has ruled (2)
5. The following are the requisites for
Based on the facts of the case
6. In order that a case for (i.e. B.P. 22) to prosper, the
Therefore/Consequently . . . following elements must be attendant/present:

The. . . . is proper/tenable/untenable 7. To constitute (i.e. homicide), the following requisites must

It is a well settled rule/As provided for under the
8. (i.e. Legal compensation) requires the concurrence of the
Moreover . . ..Hence/Therefore following conditions:

Under the provisions of RA/Constitution/Law/Statute. . . . 9. To establish a persons culpability under (i.e. estafa), it is
On the problem at hand..,..Consequently
On the other hand.
As such it should be ruled
When being asked to distinguish, do not state its definition. If you
ENUMERATION give its definition, you are in effect asking the examiner to extract
out the differences of the two [or more] from your definition. Do not
The real secret in remembering the matters contained in an
also give their similarities. You are asked to differentiate and
enumeration is the use of keywords. Make your keywords on
contrast, so similarities are not included. The number of distinctions
enumerations you consider important. Never leave a blank in an
you will give must also be proportionate on the points allotted for
enumeration! However, if you use the letters a, b, c, etc. for
such. If it is only worth two points, do not give 8 distinctions. The
numbers in the enumeration, so much the better. Ten to one, the
examiner cannot give you 8 points for that. For a two point
examiner may not count his fingers. Make the first four in the
distinction question, perhaps, three would be enough (four is not
enumeration definitely good.
too much).
If you can enumerate all, write it in bulleted or numbered form to
1. The (i.e. two) may be distinguished from each other in the
highlight the fact that you know all of them and for more
b. 1. Finishing is the key. Many fail the Bar exam because they
dont finish the exam. They spend so much time on an
2. In the first, it is necessary that there be.., whereas in the early question that they cant finish the later ones. Or they
second it is sufficient that there be . work on all of the questions at once, but without finishing
some or all of them. Either way, these Bar candidates are
3. In the former, while in the latter
writing too slowly, and it costs them their ticket to a law
license. Focus on one question at a time. Dont bother or
4. The former requires while the latter
think of another question while answering one.
5. on the other hand ______________ is
2. Budget your time according to the number of questions
DEFINITION and length of problems. Check the point percentage
allocation for each question. This will be your guide on
1. ________________ is a comprehensive term used to how much time you will spend for a question. Of course,
describe _______. you will devote more minutes to questions with a big or
higher percentage (i.e. 5%; 10%) than questions with a
2. _________________, in its generally accepted sense, minimum point percentage (i.e. 1%; 2%).
refers to .
3. Set a time schedule. Its easy to waste time by getting
3. It is a safeguard and guarantee provided by the 1987 carried away by a single question or by getting stuck on a
Constitution.. question thats giving you trouble. Make a general
allocation for each question and adjust the time
4. It is a kind of relief granted to a ______________ by the
depending on their percentage weight. Monitor your pace

so that you stay calm and will be able to answer all
5. ________________ is a branch of public law (or private questions on the exam.
law) which deals with..
4. If the question is lengthy, read first what is required at the
6. It pertains to bottom of the question. By doing this, you will be able to
determine what facts do you need and what facts are
7. It connotes a . immaterial. This will save you time from re-reading the
question. You can also start formulating your answer in
8. is a doctrine in (i.e. Civil Law) which refers to mind while reading the question, thus, it will be easier and
faster for you to write your answers since you are already
9. is a principle in (i.e. Criminal Law) which states that guided by your earlier analysis. It will also minimize errors
and erasures.
10. It presupposes
5. Be reminded that one of your tasks while preparing for the
11. Its principal identifying feature is..
Bar exam is to become an expert fact pattern reader. So
12. It is akin to what do you do if you arent very good at reading facts?
You need to experiment with different ways to get better
13. The function of which is to at reading facts. Practice answering past Bar questions as
many as you can. Analyze the suggested answers and take
14. The office of which is to note how the answers used the facts in the problem.
Remember, you wont get all the possible points if you
REASON BEHIND THE LAW/CONCEPT/PRINCIPLE dont understand what the Bar examiners are asking you.
You must become an expert fact reader in order to write a
1. The purpose of the law is
complete exam answer.
2. The law is designed to
6. Before answering, formulate on your mind what will be
3. It is intended to shield placed on your first, second and third paragraphs.
Mentally apply your outline. The first paragraph normally
4. It is primarily aimed at protecting ____________ from contains a one-sentence direct to the point answer to the
unwarranted ____ question. The second paragraph commonly contains legal
basis (provision of law in point, jurisprudence, co-relation
5. The rationale behind the law is of the jurisprudence/provision with the facts of the case
and application). Third paragraph normally contains the
6. The spirit of the law is to the effect that
conclusion. When you are already decided of your answer,
write it according to your thoughts. In this approach, you
will not only be avoiding unnecessary revisions and
erasures, you will also maintain the cleanliness of your automatic by exam day that you move from one step to
booklet. Bear in mind that, a dirty booklet is irritating to the other without missing a beat.
the eyes of the person checking the same.
14. At least twice during your bar prep (ideally four), do a
7. Use logic or common sense when you do not know the simulated Bar exam day. Do a mock version of it. The key is
answer. Ask the question, What is the best solution or to practice under conditions similar to the actual Bar
resolution for this case? or If I were the examiner how examinations. This will make you mindful of time
do I want the question answered? Do not just guess, constraints and more comfortable when you approach the
make a smart guess. Your best guide is to think what is real test, the Bar exam.
most just and equitable since these are the purpose any
law seeks to achieve. 15. Finally, PRAY!

8. If you really have no idea on how to answer a really The task ahead of us is not as great as the Power behind us.
difficult question, or a borderline case, or you do not know
May the Force be with you!!!
what the answer is, the use of inverted pyramid of
answering question may be helpful. This may be done by
inverting the usual answer format. Initially, present your
knowledge of the law and/or jurisprudence, then make
your smart guess. With this, you may be able to show or
convince the examiner that you know something about
the issue but you were merely incorrect in your
conclusion, you may get a credit for your answer.

9. Number your answer accordingly. Dont make the

Examiner search for your answers. Make your answer look
professional. Dont use textspeak and dont abbreviate.
Answers which look professional, are well organized and
which use paragraphs and indenting where appropriate
make the Examiners job easier.

10. An answer to one question in one problem requires a

separate page. Answers to sub-questions may be
presented continuously in a page separated by space/s. It
is suggested, however, that even answers to sub-questions
be presented on separate page, unless your answer is very
short, so that in case you want to change any or in case
you have missed a sub-question, you can still insert your
answer in the remaining spaces of the page.

11. Dont submit your test booklet too early. Theres no prize
for early finishers. Budget and utilize all the time allocated
for you to: (a) compose good answers; (b) review your
answers; and (c) write legibly.

12. Practice, practice, practice. Practice is vital to your success

in the Bar exam. You must get used answering Bar essay
questions. The only way to know if you can (or if you know
the law) is to practice. Answering Bar questions regularly
will help you learn the law as well as become a better
tester. There are many sample bar exam essay questions
and answers available on the internet. You may also find
the Q&A published by the UP Law Center helpful.

13. The key to success in any endeavor is preparation.

Familiarity with the structure of the essay questions and
how you respond to them will go a long way in alleviating
your anxiety on test day. You job is to practice the
approach weve just outlined so that it becomes so