MANILA, Philippines — A bar review coach who passed the 2016 Philippine Bar Examinations has been found guilty of indirect contempt by the Supreme Court after a social-media post claimed that artificial intelligence would be used to check the 2023 Bar examinations.
The Supreme Court En Banc ruled against Edgar S. Dizon, administrator of the Facebook group Bar Law for Dummies, imposing a ₱30,000 fine and directing the Office of the Bar Confidant to remove his name from the list of 2016 Bar passers. The Court also warned him against further engaging in the unauthorized practice of law.
The post that triggered the case
The controversy began on September 21, 2023, when posts associated with Bar Law for Dummies and the account Tsidkenu Dizon claimed that the 2023 Bar Examinations would be “sorted, checked, and corrected” using artificial intelligence.
The posts also suggested that examinees should structure their answers in a particular way because of supposed AI checking.
The claims spread online while examinees were making their final preparations for the Bar. The Office of the 2023 Bar Chair, headed by Associate Justice Ramon Paul L. Hernando, investigated the posts and their possible impact on the examination.
Bar officials subsequently issued an advisory rejecting the claim and explaining that the examinations would be checked by four human examiners for each subject, all recognized experts in their respective fields.
The Supreme Court later said the misinformation created confusion and anxiety among examinees and forced Bar officials to devote time and resources to identifying the source of the posts, coordinating with other agencies, issuing clarifications and responding to inquiries.
Dizon challenged the Court’s response
Rather than removing the posts, Dizon sought media attention and demanded an apology from the Supreme Court, while also threatening legal action, according to the Court’s findings.
He later acknowledged that he controlled the Facebook accounts involved.
Dizon disputed the interpretation of his post, arguing that he did not actually claim AI would independently check the examinations. The Supreme Court, however, rejected his explanation and found that the publication conveyed the impression that AI would be responsible for sorting, checking or correcting Bar answers.
The bigger issue: Was he even authorized to practice law?
The case went beyond the disputed Facebook post.
The Supreme Court noted that Dizon had passed the 2016 Bar Examinations after graduating from Arellano School of Law. However, he had not taken the lawyer’s oath, meaning he had not completed the requirements necessary to practice law.
The Court also found that Dizon had conducted Bar review coaching and prepared review materials covering various areas of law through the Bar Law for Dummies training program.
According to the ruling, those activities involved the application of legal knowledge and constituted unauthorized practice of law.
Why the Supreme Court imposed the maximum fine
The Court cited provisions of Rule 71 of the Rules of Court concerning indirect contempt, including conduct that unlawfully interferes with court processes, degrades the courts or undermines public confidence in the administration of justice.
The Supreme Court concluded that the false information about the 2023 Bar examinations interfered with the conduct and integrity of the examinations.
It also pointed to Dizon’s refusal to remove the posts and what the Court characterized as a lack of remorse after the controversy erupted.
The Court therefore imposed a ₱30,000 fine, the amount provided under the applicable rule for indirect contempt involving the Supreme Court.
But the more consequential penalty was the order directing the Office of the Bar Confidant to delist Dizon from the roster of 2016 Bar passers and report compliance to the Court.
Supreme Court stresses integrity of the Bar
The ruling underscores the Supreme Court’s role as the institution responsible for supervising the Philippine legal profession and the Bar examinations.
The Court emphasized that passing the Bar does not, by itself, mean a person is authorized to practice law. The required steps include taking the lawyer’s oath and complying with the other requirements governing admission to the legal profession.
The decision also carries a broader warning for social-media users involved in legal education and Bar review: claims concerning the administration or checking of the Bar can have consequences when they create confusion or undermine confidence in the examination process.
Free speech issue also raised
The ruling was not without a broader constitutional question.
In a separate concurring opinion, Senior Associate Justice Marvic M.V.F. Leonen agreed that Dizon should be sanctioned for conduct that undermined the integrity of the Bar examinations.
However, Leonen also emphasized the importance of balancing the Supreme Court’s contempt powers with the constitutional protection of free speech, including legitimate criticism of the courts.
The case therefore goes beyond a single controversial Facebook post. It raises questions about the limits of online commentary concerning judicial proceedings, the responsibilities of Bar review providers, and where legitimate criticism ends and conduct that interferes with the administration of justice begins.
For Dizon, however, the immediate consequence is clear: a ₱30,000 contempt fine, removal from the 2016 Bar passers list and a warning against unauthorized practice of law.
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