MANILA — A bar review coach has been found guilty of indirect contempt by the Supreme Court after a social media post falsely claimed that artificial intelligence would be used to sort, check and correct answers in the 2023 Bar Examinations.
The Supreme Court En Banc found Edgar S. Dizon, administrator of the Facebook group Bar Law for Dummies, liable for indirect contempt and imposed a ₱30,000 fine. The Court also ordered the Office of the Bar Confidant to remove Dizon’s name from the list of 2016 Bar passers and warned him against further engaging in the unauthorized practice of law.
The controversy began on September 21, 2023, when posts from the Bar Law for Dummies Facebook group and the account of Tsidkenu Dizon claimed that the 2023 Bar examinations would be “sorted, checked, and corrected” using artificial intelligence.
One portion of the post advised examinees to begin their answers with “yes” or “no,” claiming that this was what an alleged AI checking system would first look for in sorting correct answers. The posts subsequently circulated widely online, triggering concern and anxiety among examinees preparing for one of the country’s most important professional examinations.
The Office of the 2023 Bar Chair, headed by Associate Justice Ramon Paul L. Hernando, investigated the source of the information and its potential impact on the examinations.
The Supreme Court then clarified that the claim was false.
According to reports on the ruling, the 2023 Bar Examinations were to be checked by four human examiners for each subject, all experts in their respective fields. The examiners were not artificial-intelligence systems.
The Court said the misinformation created confusion and alarm at a particularly sensitive time, forcing bar officials to spend time tracing the source of the post, coordinating with relevant agencies, issuing clarifications and responding to inquiries from concerned examinees.
Instead of removing the post, Dizon reportedly sought media attention and demanded that the Supreme Court issue an apology within 24 hours. He also threatened legal action against the Court.
Dizon denied that he had claimed AI would actually conduct the checking of the examinations. He argued that his post merely referred to AI as something that would “help” in the process.
The Supreme Court rejected that explanation.
The Court pointed to the wording of his post, which expressly referred to AI checking and sorting answers, concluding that the statement conveyed that artificial intelligence would be involved in determining correct answers.
Why the Supreme Court considered it contempt
The Court ruled that Dizon’s conduct went beyond ordinary criticism or commentary because it interfered with a court-sanctioned process.
Under Rule 71 of the Rules of Court, indirect contempt includes unlawful interference with the proceedings or processes of a court outside its presence, conduct that tends to degrade or undermine the administration of justice, and other acts covered by the rule.
The Supreme Court said Dizon’s post undermined confidence in both the integrity of the Bar Examinations and the Court itself, which exercises supervision over the legal profession.
The Court also took into account Dizon’s status as someone who had himself passed the 2016 Bar Examinations. According to reports on the decision, he should have known that the Bar examinations are overseen by a committee of examiners appointed under the authority of the Supreme Court.
Another issue: unauthorized practice of law
The case did not end with the false AI claim.
The Supreme Court also found that Dizon’s bar review activities raised concerns about unauthorized practice of law.
Dizon had passed the 2016 Bar Examinations but had not taken the lawyer’s oath. Reports on the ruling said he had not been admitted to the practice of law because of pending criminal cases.
Despite this, he conducted bar review coaching sessions and prepared review materials covering various legal subjects through the Bar Law for Dummies training program.
The Supreme Court held that preparing such materials and providing coaching that required the application of legal knowledge constituted unauthorized practice of law.
The Court therefore warned Dizon against engaging in any further unauthorized practice of law.
A warning about misinformation and the Bar
The ruling highlights the potentially serious consequences of spreading unverified information involving the Bar Examinations, particularly when such claims can affect thousands of examinees already under enormous pressure.
The Supreme Court has emphasized that while legitimate criticism and public discussion involving the Judiciary remain protected, statements that interfere with court processes or undermine the administration of justice can cross the line into punishable conduct.
In a separate concurring opinion, Senior Associate Justice Marvic M.V.F. Leonen agreed that Dizon should be sanctioned for undermining the integrity of the Bar Examinations, while also stressing the importance of balancing the Court’s contempt powers with the constitutional protection of free speech.
For future Bar examinees, the message is clear: viral social-media claims about examination procedures should not be treated as official information unless confirmed by the Supreme Court or the Office of the Bar Confidant.
What began as a social-media claim about AI checking the Bar ultimately resulted in a ₱30,000 contempt penalty, the removal of a Bar passer from the official list, and a judicial warning over unauthorized legal practice.
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