6. OSCAR B. PIMENTEL, ET AL. V. LEGAL EDUCATION BOARD (LEB), G.R NO.

230642,
SEPTEMBER 10,, 2019/ FRANCIS JOSE LEAN L. ABAYATA, ET AL. V. HON. SALVADOR
MEDIALDEA AND LEGAL EDUCATION BOARD, G, R NO. 242954, SEPTEMBER 10, 2019.
FACTS: On December 23, 1993, Congress passed RA 7662 for the improvement of the system of
legal education on account of poor performance in the bar examinations. It was declared the
policy of the State to uplift the standards of legal education. RA 7662 is the same act which
created the Legal Education Board. Substantively,in G.R No. 230642, petitioners argue that R.A
7662 and the PhilSAT or the Philippine Law School Aptitude Test, which require prospective
law students to pass such exam before they could enrol into any law school institution in the
country. Petitioners-in-intervention meanwhile contend that the PhilSAT violates the right to
liberty and protection clause as it is an arbitrary form of classification not based on substantial
distinctions. It is also their position that the PhiLSAT violates due process as it interferes with
the right of every person to select a profession or course of study. The same contentions were
raised in G.R No. 242954, adding that the consequent forfeiture of school fees and the ban on
enrollment for those who failed PhilSAT violates due process. In addition, they argue that the
PhiLSAT issuances violate academic freedom, and that the LEB is not authorized to revoke
conditional enrollment nor is it authorized to forfeit school fees and impose a ban enrollment
which are penal sanctions violative of the due process clause. They also argue that the
classification of students to those who have passed or failed the PhiLSAT for purposes of
admission to law school is repugnant to the equal protection clause.
ISSUE: (1) Whether or not PhiSAT violates prospective law student’s right to liberty, equal
protection clause, and due process of law; and (2) Whether or not supervision of legal
education is a valid exercise of police power.
HELD: The court having examined various provisions of the Constitution and other rules of
court governing the supervision and control of legal education in all law schools, ruled that the
regulation and supervision of legal education do not fall within the competence of the Court and
is, instead, a power exercised by the political departments. Consequently, it ruled that enactment
of education laws is an exercise of police power. The State has a "high responsibility for the
education of its citizens and has an interest in prescribing regulations to promote the education,
and consequently, the general welfare of the people. The regulation or administration of
educational institutions is invested with public interest. Thus, the enactment of education laws,
implementing rules and regulations and issuances of government agencies is an exercise of the
State's police power. As a professional educational program, legal education properly falls within
the supervisory and regulatory competency of the State. The State, may be considered as having
properly exercised its police power only if the following requirements are met: (1) the interests
of the public generally, as distinguished from those of a particular class, require its exercise;
and (2) the means employed are reasonably necessary for the accomplishment of the purpose.
In sum, the avowed purpose of the PhiLSAT is to improve the quality of legal education by
evaluating and screening applicants to law school. As elucidated, the State has an interest in
improving the quality of legal education for the protection of the community at-large, and
requiring an entrance test is reasonably related to that interest. In other words, the State has the
power and the prerogative to impose a standardized test prior to entering law school, in the same
manner and extent that the State can do so in medical school when it prescribed the NMAT.
Therefore, the PhilSAT is a valid exercise of police power though some provisions of the
assailed law is unconstitutional.