philippine bar examination 12.1 -...
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Philippine Bar Examination
From Wikipedia, the free encyclopedia
The Philippine Bar Examination is the professional
licensure examination for lawyers in the Philippines.
It is the only professional licensure exam in the
country that is not supervised by the Professional
Regulation Commission. The exam is exclusively
administered by the Supreme Court of the Philippines
through the Supreme Court Bar Examination Committee.
Contents
1 Brief history
2 Admission requirements
3 Committee of Bar Examiners
4 Bar review programs
5 Venue and itinerary
6 Coverage
7 Grading system
o 7.1 Passing average vs. Passing rate
o 7.2 Passing Percentage (1978-2012)
o 7.3 Law school passing rates
o 7.4 Role of the Supreme Court, Criticisms
o 7.5 Bar topnotchers
7.5.1 Highest and lowest topnotcher
grades
7.5.2 Highest scores in specific bar
subjects
8 Increasing difficulty
9 Waiting period
10 Admission of successful bar examinees
11 Controversies
12 Bar Topnotchers List
o 12.1 Famous bar topnotchers
12.1.1 Presidents and Vice-
Presidents
12.1.2 Supreme Court and Court of
Appeals Justices
12.1.3 Senators and Representatives
12.1.4 Appointees and career service
officials
12.1.5 Local officials
12.1.6 Academe
12.1.7 Private sector
13 1st place in the Philippine Bar Examinations
14 External links
15 See also
16 References
Brief history
The first Philippine Bar Exams was given in 1903 but
the results were released in 1905. Jose I. Quintos
obtained the highest rating of 96.33%, Sergio Osmena,
Sr. was second with 95.66%, F. Salas was third with
94.5% and Manuel L.Quezon fourth with 87.83%. The
first bar exam was held in 1903, with 13 examinees,
while the 2008 bar examination is the 107th (given
per Article 8, Section 5, 1987 Constitution). The
2001 bar exam had the highest number of passers—1,266
out of 3,849 examinees, or 32.89%, while 2006 had the
highest examinees -.6,187. However, the Supreme Court
of the Philippines' Office of the Bar Confidant
announced that (a new and official record of) 6,533
law graduates will take the 2008 Bar examinations.[1]
The most notable was the 1999 bar examinations which
recorded the lowest passing rate of 16.59% or with a
total number of 660 successful examinees. Also, the
2003 bar exam was marred by controversy when the
Court ordered a retake of the Mercantile law due to
questionnaire leakage.[2] In 2005, the High Tribunal
implemented the "five-strike" rule, which
disqualifies five-time flunkers from taking future
bar exams.[3]
Admission requirements
A bar candidate must meet the following academic
qualifications:
Holder of a professional degree in law from a
recognized law school in the Philippines[4]
Holder of a bachelor's degree with academic
credits in certain required subjects from a
recognized college or university in the
Philippines or abroad.[5]
He or she should also meet certain non-academic
requisites:[6]
A Filipino citizen.
At least twenty-one (21) years of age.
A resident of the Philippines.
Satisfactory evidence of good moral character
(usually a certificate from the dean of law
school or an immediate superior at work).
No charges involving moral turpitude have been
filed against the candidate or are pending in
any court in the Philippines.
In March 2010 the Philippine Supreme Court Issued Bar
Matter 1153 amending provisions in sec 5 and 6 of
rule 138 of the rules of court now allowing Filipino
foreign law school graduates to take the bar exam
provided that they comply with the following: a.
completion of all courses leading to a degree of
Bachelor of laws or its equivalent b. recognition or
accreditation of the law school by proper authority
c. completion of all fourth year subjects in a
program of a law school duly accredited by the
Philippine Government d. present proof of completing
a separate bachelors degree
Committee of Bar Examiners
The Supreme Court appoints memberships in the
Committee of Bar Examiners, the official task force
for formulating bar exam questions, instituting
policy directives, executing procedures, grading bar
examination papers, and releasing the results of the
annual bar examination.[7]
The committee is chaired by an incumbent Justice of
the Supreme Court, who is designated by the Supreme
Court to serve for a term of one year. The members of
the committee includes eight (8) members of the
Integrated Bar of the Philippines, who also hold
office for a term of one year.[8] While the Justice
who shall act as Chairman is immediately known,
committee members must exert every effort to conceal
their identities until the oath-taking of the
successful bar examinees, approximately six months
after the bar exam.[9]
Bar review programs
Candidates who meet all the admission requirements
usually enroll in special review classes after
graduating from law school. These programs are held
from April to September in law schools, colleges,
universities, and review centers.
Program schedule, content, and delivery differs from
one review program to another. Lecturers in these
programs are called bar reviewers. They are usually
full-time professors and part-time professorial
lecturers in law schools and universities. Most
review programs invite incumbent and retired justices
and high ranking public officials both as a marketing
tool and as a program innovation.[10]
Venue and itinerary
In recent years, the examinations were held
during the four Sundays of September of every year at
the campus of De La Salle University-Manila along
Taft Avenue, Manila. Starting 2011, the exams will be
moved to November, and will be held at the University
of Santo Tomas' campus along España Boulevard, in
Sampaloc, Manila.
On February 8, 2011, the Supreme Court resolved to
approve changes to the Rules of Court, thereby
altering the schedule for the examinations.[11]
The
schedule is now as follows:
First Sunday:
o Political and International Law, Labor and
Social Legislation (morning session)
o Taxation (afternoon session)
Second Sunday:
o Civil Law (morning session)
o Mercantile Law (afternoon session)
Third Sunday:
o Remedial Law, Legal Ethics (morning
session)
o Criminal Law (afternoon session)
Fourth Sunday:
o Trial Memorandum (morning session)
o Legal Opinion with one legal form
(afternoon session)
Coverage
The examination covers the following topics,
popularly known as the bar subjects:[12]
Political and Public International Law
o Constitutional Law
o Political Law
o Administrative Law (only the basic
doctrines, excluding implementing rules
and regulations of government agencies)
o Law on Public Officers
o Public Corporations
o Suffrage
o Public International Law
Labor and Social Legislation
o Labor Law (Labor Code of the Philippines,
excluding the implementing rules and
regulations)
o Social Legislation
Social Security Law
Revised Government Service Insurance
Act of 1977 (including Employees
Compensation Act of 1977)
Comprehensive Agrarian Reform Law
Civil Law
o Civil Code of the Philippines (excluding
the Code of Muslim Personal Laws, Water
Code, Rental Law, Law on Sale of
Subdivision of Lots and Condominiums)
o Family Code of the Philippines (including
the Child and Youth Welfare Code)
o Property Registration Decree (excluding
the Public Land Law)
o Conflict of Laws (Private International
Law)
Taxation
o General principles of Taxation
o Republic Act No. 1125, creating the Court
of Tax Appeals
o National Internal Revenue Code (including
the Expanded Value Added Tax or EVAT)
o Tariff and Customs Code (excluding
Arrastre and Classification of
Commodities)
Mercantile Law
o Negotiable Instruments Law and Other
Allied Laws
Negotiable Instruments Law (with the
Uniform Currency Act)
Merchants and Commercial
Transactions (including Articles 1
to 63 of the Code of Commerce,
Retail Trade Law, Bulk Sales Law)
Letters of Credit under the Code of
Commerce
o Insurance Code
o Transportation Laws
Common Carriers (Articles 1732 to
1766 of the New Civil Code)
Commercial Contracts for
Transportation Over Land (Articles
349 to 379 of the Code of Commerce)
Maritime Commerce
Public Service Act
o Corporation Law
Corporation Code
Securities Act
Banking Laws
Laws on Secrecy of Bank
Deposits
Deposit Insurance Corporation
Trust Receipts Law (excluding
the General Banking Act)
Other Special Laws
Chattel Mortgage Law
Warehouse Receipts Law
Laws on Intellectual Creations
Copyright Law
Patent Law
Trademark Law
Insolvency Law
Truth in Lending Act
Criminal Law
o Revised Penal Code (Books I & II excluding
penalties for specific felonies)
o Indeterminate Sentence Law
o Probation Law
o Anti-Graft and Corrupt Practices Act
o Anti-Fencing Law
o Bouncing Checks Law
o Dangerous Drugs Act of 1972
o Heinous Crimes Law (excluding penalties)
Remedial Law
o Revised Rules of Court
o 1991 Revised Rule on Summary Procedure
o Local Government Code on Conciliation
Procedures (Chapter VII)
o Judiciary Reorganization Act of 1980
(excluding purely administrative
provisions, Military Justice Law,
Judiciary Act of 1948, and the Law
Reorganizing the Court of Agrarian
Relations)
Legal Ethics and Practical Exercises
o Legal Ethics
o Judicial Ethics
o Code of Professional Responsibility
o Grievance Procedures (Rules 139-B, Revised
Rules of Court)
o Forms
Grading system
The eight bar subjects are separately graded.
Each subject contributes to the general average in
the following proportion:[13]
Subject Weight'
Civil Law 15%
Labor Law and Social Legislation 10%
Mercantile Law 15%
Criminal Law 10%
Political and International Law 15%
Taxation 10%
Remedial Law 20%
Legal Ethics and Practical Exercises 5%
The passing average fixed by law is 75%, with
no grade falling below 50% in any bar subject.[14]
Passing average vs. Passing rate
The passing average is the minimum grade in the exam
required to be admitted to the practice of law. The
passing rate is the proportion of total number of bar
passers in relation to the total number of bar
examinees. It is usually computed on two levels—the
national level (national bar passing rate), and the
law school level (law school passing rate).
In the past, passing averages were considerably lower
to admit more new lawyers (i.e. 69% in 1947, 69.45%
in 1946, 70% in 1948). Since 1982, the passing
average has been fixed at 75%. This has led to a
dramatic decrease in the national passing rate of bar
examinees, from an all-time high of 75.17% in 1954 to
an all-time low of 16.59% in 1999 (all-time low
should have been the single digit 5% national passing
rate for the 2007 bar examination if the Supreme
Court did not lower the passing average to 70% and
lowered the disqualification rate in 3 subjects). In
recent years, the annual national bar passing rate
ranges from 20% to 30%.[15]
Passing Percentage (1978-2012)
Year Passing Percentage
2012 17.76% (949 out of 5,343)
2011 31.95% (1,913 out of 5,987)
2010 20.26% (982 out of 4,847)
2009 24.58% (1,451 out of 5,903)
2008 20.58% (1,310 out of 6,364)
2007 22.91% (1,289 out of 5,626)
2006 30.60% (1,893 out of 6,187)
2005 27.22% (1,526 out of 5,607)
2004 31.61% (1,659 out of 5,249)
2003 20.71% (1,108 out of 5,349)
Year Passing Percentage
2002 19.68% (917 out of 4,659)
2001 32.89% (1,266 out of 3,849)
2000 20.84% (979 out of 4,698)
1999 16.59% (660 out of 3,978)
1998 39.63%
1997 18.11% (710 out of 3,921)
1996 31.21% (1,217 out of 3,900)
1995 30.90% (987 out of 3,194)
1994 30.87%
1993 21.65%
1992 17.25%
1991 17.81% (569 out of 3,194)
1990 27.94% (866 out of 3,100)
1989 21.22% (639 out of 3,012)
1988 24.26% (689 out of 2,840)
1987 16.95% (480 out of 2,832)
1986 18.88% (491 out of 2,600)
1985 25.78% (701 out of 2,719)
1984 21.80% (563 out of 2,582)
1983 21.30% (523 out of 2,455)
1982 20.50% (433 out of 2,112)
1981 43.71% (841 out of 1,924)
1980 33.61% (605 out of 1,800)
1979 49.51% (903 out of 1,824)
1978 56.93% (1,076 out of 1,890)
Law school passing rates
The Legal Education Board's ranking for top ten law
schools in the Philippines is based on the passing
rate from 2001 to 2010:[16]
Excellence in Legal Education (top five)
1. University of Batangas (89.03) 2. San Beda College of Law (85.74) 3. University of the Philippines College of Law
(79.84)
4. Ateneo de Davao College of Law (64.99) 5. University of San Carlos College of Law (61.23)
Outstanding Law Schools (rest of the top ten)
1. University of Batangas (90.22) 2. Arellano University Law Foundation (42.90) 3. Xavier University - Ateneo de Cagayan College
of Law (38.90)
4. Far Eastern University Institute of Law (33.14) 5. University of San Agustin College of Law
(31.63)
Role of the Supreme Court, Criticisms
In 2007, only 5% (of the 5,626 who took the 2007
tests, or less than 300) got the passing grade of
75%. Thus, the Supreme Court adjusted the standard to
70% and the disqualification rate in 3 subjects
(civil, labor and criminal law) from 50 to 45%.
Accordingly, 1,289 or 22.91%, "passed." This passing
grade reduction is highly unusual, since it last
happened in the 1981 exam when the passing grade was
lowered to 72.5%. Prior to 1982, the passing mark
jumped unpredictably from year to year: 69.45 percent
in 1946; 69 in 1947; 70 in 1948, 1963, 1972 and 1974;
71 in 1961; 71.5 in 1953, 1964 and 1965; 72 in 1957,
1958, 1959, 1960 and 1967; 72.5 in 1954, 1962 and
1981; 73 in 1950, 1956, 1968, 1969, 1970, 1975, 1978
and 1980; 73.5 in 1955 and 1979; 74 in 1949, 1951,
1952, 1966, 1971, 1973 and 1977; and 74.5 in 1976. In
1954, the Court lowered the passing grade to 72.5%,
even if the passing percentage was already at its
highest at 75.17%. In 1999, moves to lower the
passing grade to 74% failed, after Justice Fidel
Purisima, bar committee chairman failed to disclose
that his nephew took the examination. He was censured
and his honoraria was reduced to half.[17]
Bar topnotchers
Bar topnotchers are bar examinees who garnered the
highest bar exam grades in a particular year. Every
year, the Supreme Court releases the bar top ten
list. The list contains the names of bar examinees
who obtained the ten highest grades. It is possible
for more than ten examinees to place in the top ten
because numerical ties in the computation of grades
usually occur.[18]
From 1913 to 2013, schools which have produced bar
topnotchers (1st placers) are as follows:[18]
University of the Philippines College of Law -
forty-seven (47) bar topnotchers
Ateneo de Manila Law School - twenty-one (21)
bar topnotchers
San Beda College of Law - seven (7) bar
topnotchers
Philippine Law School - five (5) bar
topnotchers
Far Eastern University Institute of Law - four
(4) bar topnotchers
University of Manila College of Law - four (4)
bar topnotchers
University of Santo Tomas Faculty of Civil Law
- three (3) bar topnotchers
University of the Cordilleras (formerly Baguio
Colleges Foundation) College of Law - two (2)
bar topnotchers
Manila Law College Foundation (formerly Escuela
de Derecho de Manila) - one (1) bar topnotcher
Manuel L. Quezon University College of Law -
one (1) bar topnotcher
Holy Name University (formerly Divine Word
College of Tagbilaran) - one (1) bar topnotcher
University of the East College of Law - one (1)
bar topnotcher
San Sebastian College - Recoletos - one (1) bar
topnotcher
New Era University - one (1) bar topnotcher
Two bar examinees topped the bar exams without
officially graduating from any Philippine law
school:[18]
Jose W. Diokno - former Senator of the
Philippines; 1st placer, 1945 bar exams. Mr.
Diokno, who tied for Number One with Mr. Jovito
Salonga in the 1945 Bar Exams, would have
graduated from the University of Santo Tomas
had not World War II supervened. Mr. Diokno's
success in the bar exams is further underscored
by the fact that he was also under-age[19]
and
that he also placed number 1 in the 1940 CPA
Board exams which he took while in law school,
after graduating summa cum laude from then De
La Salle College at the age of 17. This double
number 1 feat may never be paralleled. The
closest may have been Cesar L. Villanueva (from
the Ateneo Law School) who placed second in the
1981 Bar Exams and sixth place in the 1982 CPA
Board Exams.
Carolina C. Griño-Aquino - former Associate
Justice of the Supreme Court; 1st placer, 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 the 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.[19]
Both spouses Aquino
(in addition to being topnotchers) also served
as Justices of the Supreme Court.[20]
In the past, non-law school graduates were allowed to
take the bar. However, the Revised Rules of Court and
Supreme Court Circulars allow Filipino graduates of
Philippine law schools (and subject to certain
conditions, Filipino graduates of foreign law
schools) to take the bar, necessarily excluding non-
law graduates and foreigners who have law degrees
from taking part in the exercise.[4]
While 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. Ateneo Law
School's only summa cum laude graduate, Claudio
Teehankee, placed number one in the 1940 Bar
Exams.[18]
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
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 equalled in the annals of Philippine
Bar. For siblings, the closest is when Manuel B.
Zamora, Jr. placed third in the 1961 Bar Exams and
younger brother Ronaldo placed first in the 1969 Bar
Exams.
The UST Faculty of Civil Law's sole summa cum laude
graduate, Roberto B. Concepcion, placed first in the
1924 Bar Exams.[18]
He later served as Chief Justice
of the Supreme Court.
The San Beda College of Law's sole magna cum laude
graduate, Florenz Regalado,[21]
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 five of its seventeen
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) place number one 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.[18]
Dinglasan became a Judge of the Court of
First Instance of Manila, Sumulong became Senator of
the Republic and a renowned statesman, Eufemio and
San Jose established their respective successful
private law practices while Zamora became Executive
Secretary to then President Joseph Estrada and is
currently the Minority Leader in the House of
Representatives.
Highest and lowest topnotcher grades
A standard was created in 1940, when Claudio
Teehankee (future Supreme Court Chief Justice), from
the Ateneo Law School, got a grade of 94.35% when he
topped the examinations. This record was obliterated
four years later in 1944 when Jovito Salonga and Jose
W. Diokno tied with the highest score of 95.3%. This
was the first time that first place ended in a tie.
When they took the 1944 Bar Exams, Atty. Salonga was
an undergraduate at the UP College of Law while Atty.
Diokno (future Senator) was an undergraduate of the
University of Santo Tomas Faculty of Civil Law. After
passing the bar, Atty. Salonga (future Senate
President) went back to UP to complete his bacholer's
degree in law, earning it in 1946. The only other
instance of a tie at first place of the bar exams was
when Edwin Enrile (salutatorian of his Ateneo Law
School class) and Florin Hilbay (an honor student of
the UP College of Law) both garnered the same score
in 1999. Atty. Enrile served as Deputy Executive
Secretary to President Gloria Arroyo and as a
Professorial Lecturer at the Ateneo Law School while
Atty. Hilbay is a Professor of Law at the UP College
of Law.[19]
After another four years, the "bar" was raised a few
notches when Manuel G. Montecillo of the Far Eastern
University Institute of Law got a grade of 95.50%
when he bested all the bar examinees of 1948. The
following year, another record was set when Anacleto
C. Mañgaser, an alumnus of the Philippine Law School,
got a grade of 95.85% when he topped the 1949 bar
exams.
Ferdinand Marcos (future President of the
Philippines) of the UP College of Law scored 98.8%
when he topped the 1939 Philippine Bar Examinations.
But this result is disputed as the Supreme Court
officially recognizes Florenz D. Regalado's (San Beda
College) score of 96.7% in the 1954 Bar Examinations
as the highest score ever to be made in the
Philippine Bar. Marcos' official bar score is at
92.35%. [22]
The lowest grade was obtained by Ateneo Law School's
Mercedita L. Ona, 83.55%, 2008, which erased the
prior record of 84.10%, obtained by Adolfo Brillantes
of Escuela de Derecho de Manila (now Manila Law
College Foundation) in 1920.[18][23]
Atty. Ona was the
just the latest of women first placers. In 1930,
Tecla San Andres (an alumna of the UP College of Law
and future Senator) broke the proverbial "glass
ceiling" when she became the first woman to top the
bar with a grade of 89.4%. Ameurfina A. Melencio
(also an alumna of the UP College of Law and who
later became a Justice of the Supreme Court) has the
highest grade of all female bar topnotchers in
recorded history, when she obtained a 93.85% rating
in 1947.
Below is a listing of all 100 first-placers (from
1913 to 2012) ranked from highest to lowest in terms
of rating obtained. It should be noted however that
bar ratings are not exactly comparable from year-to-
year as the difficulty of the exams varies through
the years.
Rank Yea
r Name School Rating
1st 193
9
Ferdinand
E. Marcos
University of the
Philippines
98.800
(92.35%
Official)[24]
2nd 195
4
Florenz D.
Regalado
San Beda College
96.700
(Official)[25
]
3rd 194
9
Anacleto C.
Mañgaser
Philippine Law
School 95.850
4th 194
8
Manuel G.
Montecillo
Far Eastern
University 95.500
4th
(tie
)
194
4
Jose W.
Diokno
Special
(University of
Santo Tomas)
95.300
4th
(tie
)
194
4
Jovito R.
Salonga
University of the
Philippines 95.300
6th 194
0
Claudio
Teehankee
Ateneo de Manila
University 94.350
7th 195
2
Pedro
Samson C.
Animas
University of the
Philippines 94.250
8th 195
3
Leonardo A.
Amores
University of
Manila 94.050
9th 194
7
Ameurfina
A.
Melencio-
Herrera
University of the
Philippines 93.850
10th 200
1
Rodolfo Ma.
A.
Ponferrada
University of the
Philippines 93.800
11th
(tie
)
191
4
Manuel C.
Goyena
University of the
Philippines 93.000
11th
(tie
)
191
6
Paulino
Gullas
University of the
Philippines 93.000
11th
(tie
)
193
2
Hermenegild
o Atienza
University of the
Philippines 93.000
14th 200
2
Arlene M.
Maneja
University of
Santo Tomas 92.900
15th 198
4
Richard M.
Chiu
Ateneo de Manila
University 92.850
16th 193
7
Cecilia
Muñoz-Palma
University of the
Philippines 92.600
17th 192
9
Lorenzo S.
Sumulong
University of the
Philippines 92.500
18th 197
8
Cosme D.
Rosell
University of the
Philippines 92.475
19th 193
3
Lope C.
Quimbo
University of
Manila 92.450
20th 197
1
Henry R.
Villarica
University of the
Philippines 92.400
21st
(tie
)
195
1
Vicente R.
Acsay
University of
Manila 92.250
22nd
(tie
)
Aug
-
194
6
Gregoria T.
Cruz
University of the
Philippines 92.250
23rd 195
0
Carolina C.
Griño
Special (Colegio
de San
Agustin,Universit
y of the
Philippines)
92.050
24th
(tie
)
191
3
Manuel A.
Roxas
University of the
Philippines 92.000
24th
(tie
)
191
7
Felipe
Ysmael
University of the
Philippines 92.000
25th
(tie
)
197
7
Virgilio B.
Gesmundo
Ateneo de Manila
University 91.800
25th
(tie
)
199
8
Janet B.
Abuel
Baguio Colleges
Foundation 91.800
27th
(tie
)
193
4
Miguel
Aragon
University of the
Philippines 91.700
27th
(tie
)
196
0
Ismael
Andres
Manuel L. Quezon
University 91.700
27th
(tie
)
Nov
-
194
Pedro L.
Yap
University of the
Philippines 91.700
6
31st 197
4
Arturo D.
Brion
Ateneo de Manila
University 91.650
32nd
(tie
)
197
9
Gregorio M.
Batiller,
Jr.
Ateneo de Manila
University 91.400
32nd
(tie
)
198
3
Manuel
Antonio J.
Teehankee
Ateneo de Manila
University 91.400
34th 193
8
Emmanuel N.
Pelaez
University of
Manila 91.300
35th 199
5
Leonor Y.
Dicdican
University of the
Philippines 91.200
36th 192
5
Rafael
Dinglasan
University of the
Philippines 91.100
37th
(tie
)
196
1
Avelino V.
Cruz San Beda College 90.950
37th
(tie
)
198
1
Irene
Ragodon-
Guevarra
Ateneo de Manila
University 90.950
37th
(tie
)
198
2
Ray C.
Espinosa
Ateneo de Manila
University 90.950
40th 192
3
Roque V.
Desquitado
University of the
Philippines 90.900
41st
(tie
)
196
2
Deogracias
G. Eufemio
University of the
Philippines 90.800
41st
(tie
)
197
6
Enrique Y.
Teehankee
University of the
Philippines 90.800
43rd
(tie
)
196
6
Roberto V.
San Jose
University of the
Philippines 90.600
44th 199 Patricia University of the 90.600
(tie
)
6 Ann T.
Prodigalida
d
Philippines
44th
(tie
)
200
0
Eliseo M.
Zuñiga, Jr.
University of the
Philippines 90.600
47th 195
5
Tomas P.
Matic, Jr.
Far Eastern
University 90.550
48th
(tie
)
192
8
Filomeno B.
Pascual
Philippine Law
School 90.300
48th
(tie
)
197
3
Vicente R.
Solis
Ateneo de Manila
University 90.300
50th
(tie
)
194
1
Emmet P.D.
Shea
University of the
Philippines 90.200
50th
(tie
)
195
6
Francisco
C. Catral San Beda College 90.200
52nd 199
7
Ma. Cecilia
H.
Fernandez
University of the
Philippines 90.025
53rd 191
5
Francisco
Villanueva,
Jr.
University of the
Philippines 90.000
54th 199
1
Joseph P.
San Pedro
Ateneo de Manila
University 89.950
55th
(tie
)
193
6
Diosdado P.
Macapagal
University of
Santo Tomas 89.850
55th
(tie
)
199
0
Aquilino L.
Pimentel
III
University of the
Philippines 89.850
57th 196
5
Victor S.
dela Serna San Beda College 89.800
58th 198 Rafael R. University of the 89.750
0 Lagos Philippines
59th 193
4
Marciano P.
Catral
Philippine Law
School 89.700
60th 196
7
Rodolfo D.
Robles San Beda College 89.600
61st
(tie
)
193
0
Tecla San
Andres
University of the
Philippines 89.400
61st
(tie
)
193
1
Jose
Leuterio
University of the
Philippines 89.400
61st
(tie
)
198
5
Janette
Susan L.
Peña
University of the
Philippines 89.400
64th 195
8
Manuel G.
Abello
University of the
Philippines 89.250
65th
(tie
)
195
9
Agustin O.
Benitez
Far Eastern
University 89.200
65th
(tie
)
199
4
Francisco
Noel R.
Fernandez
University of the
Philippines 89.200
67th 195
7
Gregorio R.
Castillo
University of the
Philippines 89.150
68th
(tie
)
192
1
Pablo
Payawal
University of the
Philippines 89.100
68th
(tie
)
192
2
Amado L.
Velilla
University of the
Philippines 89.100
68th
(tie
)
192
4
Roberto B.
Concepcion
University of
Santo Tomas 89.100
71st 201
0
Cesareo
Antonio S.
Singzon,
Jr.
Ateneo de Manila
University 89.000
72nd 198
6
Laurence L.
Go
Ateneo de Manila
University 88.600
73rd 198
7
Mario P.
Victoriano
Ateneo de Manila
University 88.550
74th 200
3
Aeneas Eli
S. Diaz
Ateneo de Manila
University 88.530
75th
(tie
)
199
9
Edwin R.
Enrile
Ateneo de Manila
University 88.500
75th
(tie
)
199
9
Florin T.
Hilbay
University of the
Philippines 88.500
77th 196
4
Jesus P.
Castelo San Beda College 88.400
78th 199
3
Anna Leah
Fidelis T.
Castañeda
Ateneo de Manila
University 88.325
79th 198
8
Maria
Yvette O.
Navarro
University of the
Philippines 88.120
80th 192
6
Eugeniano
Perez
Philippine Law
School 88.100
81st 192
7
Cesar
Kintanar
University of the
Philippines 87.700
82nd 200
6
Noel Neil
Q. Malimban
University of the
Cordilleras 87.600
83rd 197
0
Romulo D.
San Juan
Far Eastern
University[26]
87.500
84th
(tie
)
196
8
Oscar B.
Glovasa
Divine World
College of
Tagbilaran
87.450
84th
(tie
)
200
4
January A.
Sanchez
University of the
Philippines 87.450
86th 196
9
Ronaldo B.
Zamora
University of the
Philippines 87.300
87th 200
5
Joan de
Venecia
University of the
Philippines 87.200
88th 197
2
Januario B.
Soller, Jr.
Ateneo de Manila
University 87.130
89th
(tie
)
191
8
Alejo
Labrador
University of the
Philippines 87.000
89th
(tie
)
191
9
Gregorio
Anonas
Philippine Law
School 87.000
89th
(tie
)
199
2
Jayme A. Sy
Jr.
Ateneo de Manila
University 87.000
92nd 197
5
Nicanor B.
Padilla,
Jr.
University of the
East 86.700
93rd 196
3
Cornelio C.
Gison
Ateneo de Manila
University 86.350
94th 198
9
Gilberto C.
Teodoro,
Jr.
University of the
Philippines 86.185
95th 201
3
Nielson G.
Pangan
University of the
Philippines 85.800
96th 200
8
Judy A.
Lardizabal
San Sebastian
College 85.700
97th 201
2
Ignatius
Michael D.
Ingles
Ateneo de Manila
University 85.640
98th 201
1
Raoul
Angelo D.
Atadero
Ateneo de Manila
University 85.536
99th 200
9
Reinier
Paul R.
Yebra
San Beda College 84.800
100t
h
192
0
Adolfo
Brillantes
Escuela de
Derecho 84.100
Highest scores in specific bar subjects
While no bar examinee has ever reached a 100% general
average, several bar examinees have garnered perfect
and near-perfect grades in specific bar subjects.
In 1930, Tecla San Andres-Ziga (future Senator) of
the University of the Philippines got a grade of 99%
in Remedial Law.[27]
She also placed number one in the
bar exams of the same year.
In 1949, Anacleto C. Mañgaser of the Philippine Law
School earned 100% in Mercantile Law, and placed 1st
in the bar exams of that year. His average of 95.85%
broke all prior records before it was bested by
Florenz Regalado in 1954.[18]
Mañgaser's bar rating
remains the second highest of all time.
In 1953, Juan Ponce Enrile (future Defense Minister
and Senate President) of the University of the
Philippines College of Law, where he graduated
salutatorian and cum laude, earned 100% in Mercantile
Law[28]
and placed 11th in the bar exams of that
year.[28]
In 1955, Raul Gonzales (future Congressman, Secretary
of Justice and Chief Presidential Legal Counsel) of
the University of Santo Tomas Faculty of Civil Law
earned 99% in Remedial Law[citation needed]
and 95% in
International Law.[citation needed]
However, he did not
place in the top ten.[18]
In 1973, Renato Franciso (Executive Judge of RTC
Malolos, Bulacan) of the Ateneo de Manila Law School
obtained a perfect score of 100% in Criminal Law.[29]
In 1997, Maria Celia H. Fernandez of the University
of the Philippines College of Law, where she
graduated salutatorian and cum laude, earned 100% in
Legal Ethics[citation needed]
and emerged as the year's bar
topnotcher.[18]
In 2001, Rodolfo Ma. A. Ponferrada, that year's
valedictorian of the University of the Philippines
College of Law, obtained a perfect score of 100% in
Remedial Law[citation needed]
, the highest weighted of the
bar subjects. The difference (3.75%) between his
final bar examination score (93.80%) and that of the
second-placer, Jesus Paolo U. Protacio (90.05%), that
year's valedictorian of the Ateneo de Manila Law
School and who got a perfect score of 100% in
Criminal Law,[citation needed]
is the highest of all time.
Notably, that year's valedictorian of the San Beda
College of Law, Adonis V. Gabriel, obtained a perfect
score of 100% in Political Law[citation needed]
and placed
8th (88.25%).[18][30]
The 3.75% difference between No. 1
and No. 2 eclipsed the previous highest difference of
2.10% registered in 1966 when Roberto V. San Jose
(valedictorian of the UP College of Law) garnered a
grade of 90.6% versus the 88.5% of the tied second
placers, Ruben F. Balane (salutatorian of the UP
College of Law) and Pablo S. Trillana III
(valedictorian of the San Beda College of Law).
In 2005, Gladys V. Gervacio of the University of
Perpetual Help-Rizal earned a perfect 100% in two bar
subjects—Legal Ethics[citation needed]
and Labor Law[citation
needed]. She placed 6th in the bar exams of that year.
In 2011, she passed the California State Bar
examinations.[18]
Increasing difficulty
The difficulty of the recent bar examinations,
compared to exams of the past, can be attributed to
the following factors:[15]
The growing volume of Philippine case and
statutory laws is unprecedented. Laws,
jurisprudence, and legal doctrines of the past
constitute only a small fraction of
contemporary Philippine legal materials, which
are increasing on a daily basis.[31]
The 75% passing average with no grade lower
than 50% in any subject is already fixed by
law. Actual candidates who scored 74.99% in the
general average were not admitted to the
practice of law, unless they retake the bar
exams.[15]
The Three-Failure Rule is now in place.
Candidates who have failed the bar exams for
three times are not permitted to take another
bar exam until they re-enroll and pass regular
fourth-year review classes and attend a pre-bar
review course in an approved law school.[32]
The Five-Strike Rule is implemented since 2005.
The rule limits to five the number of times a
candidate may take the Bar exams. The rule
disqualifies a candidate after failing in three
examinations. However, he is permitted to take
fourth and fifth examinations if he
successfully completes a one year refresher
course for each examination.[33]
The four-year bachelor's degree is required
before admission to law school. Hence, every
bar examinee has to hold at least two degrees—
one in law and one in another field. In the
past, law schools readily admit high school
graduates and two-year Associate in Arts degree
holders.[34]
After the end of the Second World War, the passing
rate in the succeeding years was remarkably high,
ranging from 56 to 72% percent. However, after
Associate Justice J.B.L. Reyes, a noted scholar, was
appointed Chairman of the 1955 Bar Examinations, the
passing rate for that year dropped dramatically to
26.8%, with a mortality rate of 73.2%. That ratio has
been invariably maintained in the 50+ years since.[35]
Waiting period
The largely essay-type exams are manually checked by
members of the Committee of Bar Examiners. Candidates
have to wait from the last Sunday of the bar exams in
September up to the date of the release of results,
which traditionally happens before or during the Holy
Week (the last week of March or the first week of
April) of the following year.
During this period, candidates (who already hold law
and bachelor's degrees) may opt to work in law firms
and courts as legal researchers, teach in liberal
arts and business colleges, function in companies and
organizations using their pre-law degrees (i.e.
Communication Arts, Accounting, Economics,
Journalism, etc.), help run the family business, or
take a long vacation.[36]
Admission of successful bar examinees
The Office of the Bar Confidant of the Philippine
Supreme Court releases the Official List of
Successful Bar Examinees, usually during the last
week of March or the first week of April of every
year. Candidates whose names appear in the list are
required to take and subscribe before the Supreme
Court the corresponding Oath of Office.[37]
Candidates shall take an Oath of Office and sign
their names in the Roll of Attorneys of the Supreme
Court.[38]
The oath-taking is usually held in May at
the Philippine International Convention Center (PICC)
with a formal program where all Justices of the
Supreme Court, sitting en banc, formally approve the
applications of the successful bar candidates. The
eight bar examiners are officially introduced to the
public. A message to the newly inducted lawyers is
delivered by one of the justices. Candidates who made
the bar top ten list are also introduced and honored.
The deans of all Philippine law schools are requested
to attend the ceremony and grace the front seats of
the plenary hall.[12]
Controversies
In the 1930s, a distant relative of Imelda Romualdez
Marcos who was a Justice in the High Court resigned
after a controversy involving the bar examinations.
Justice Ramon Fernandez was forced to protect his
name and honor when he resigned because of a bar
examination scandal.[1]
On November 23, 1979, the High Court, per Justice
Pacifico de Castro ordered new examinations in labor
and social legislation and taxation.
On May 7, 1982, 12 of the Supreme Court's 14 justices
resigned amid expose "that the court fixed the bar-
examination score of a member's son so that he would
pass." Justice Vicente Ericta was accused to have
personally approached the bar chairman to inquire
whether his (Ericta's) son passed the bar. Ferdinand
Marcos accepted the resignations and appointed the
new Justices. Chief Justice Enrique Fernando wept at
a news conference as he accepted responsibility for
rechecking and changing the exam score of Gustavo
Ericta, son of Justice Vicente Ericta.[39]
Associate Justice Fidel Purisima, chairman of the bar
committee, did not disclose that he had a nephew who
was taking the bar examination in that year. He was
merely censured and his honoraria as bar examiner
were forfeited.
On September 24, 2003, the Supreme Court, per a
bleary-eyed Associate Justice Jose Vitug, annulled
the tests results on mercantile law after
"confirmation of what could be the most widespread
case of cheating in the 104-year-old bar exams".[40]
Bar Topnotchers List
The Office of the Bar Confidant releases an official
Bar Topnotchers list list together with the list of
names of all successful bar examinees. The Bar
Topnotchers list contains the names of the candidates
who garnered the highest general averages in the bar
exam for that year. The highest ranking candidate in
the list is known as the bar topnotcher. The list has
always been the subject of much media attention and
public speculation.[41]
Making a place in the list is widely regarded as an
important life achievement, an attractive
professional qualification, and a necessary
improvement in a lawyer's professional and social
status.[41]
Famous bar topnotchers
Prominent lawyers who made the bar top ten
include:[42][43][44][45][46][47][48][49][50][51]
Presidents and Vice-Presidents
Manuel A. Roxas - fifth President of the
Philippines; 1st placer (92%), 1913 Bar Exams
(UP)
Diosdado P. Macapagal - ninth President of the
Philippines; 1st placer (89.85%), 1936 Bar
Exams (UST)
Ferdinand E. Marcos - tenth President of the
Philippines; 1st placer (98.80%), 1939 Bar
Exams (UP)
José P. Laurel - third President of the
Philippines; 2nd placer, 1915 Bar Exams (UP)
Elpidio C. Quirino - sixth President of the
Philippines; 2nd placer, 1915 Bar Exams (UP)
Sergio S. Osmeña - fifth President of the
Philippines; 2nd placer, 1903 Bar Exams (UST)
Manuel L. Quezon - second President of the
Philippines; 4th placer, 1903 Bar Exams (UST)
Carlos P. García - eighth President of the
Philippines; 7th placer, 1923 Bar Exams (PLS)
Emmanuel N. Pelaez - former Vice-President of
the Philippines; 1st placer, 1938 Bar Exams
(UM)
Arturo M. Tolentino - former Vice-President of
the Philippines; 2nd placer, 1934 Bar Exams
(UP)
Incidentally, each President who happened to be a
lawyer was also a bar placer. In the 2010
presidential elections, candidate Gilberto Teodoro
(an alumnus of the University of the Philippines)
placed first in the 1989 Bar Exams, with a grade of
86.185%. He however was fourth in the elections,
losing to Benigno S. Aquino III. A lawyer, Jejomar C.
Binay (also from UP), won the Vice-presidency when he
bested former Senator Manuel A. Roxas II (a grandson
of the first bar topnotcher, President Manuel A.
Roxas).
Two other topnotchers have sought previously failed
to secure the presidency. Vice-President Pelaez (1938
Bar Topnotcher) lost the Nacionalista Party
nomination to President Marcos (1939 Bar Topnotcher)
in the 1965 presidential elections, while Senate
President Jovito Salonga (1944 Bar Topnotcher) of the
Liberal Party lost to President Ramos of Lakas-NUCD
in the 1992 presidential elections.[52]
Supreme Court and Court of Appeals Justices
José Yulo - 6th Philippine Chief Justice; 3rd
placer, 1913 Bar Exams (UP College of Law)
Ricardo Paras - 8th Philippine Chief Justice;
2nd placer, 1913 Bar Exams (UP College of Law)
César Bengzon - 9th Philippine Chief Justice;
2nd placer, 1919 Bar Exams (UP College of Law)
Roberto Concepcion - 10th Philippine Chief
Justice; 1st placer, 1924 Bar Exams (UST
Faculty of Civil Law)
Querube Makalintal - 11th Philippine Chief
Justice; 7th placer, 1933 Bar Exams (UP College
of Civil Law)
Enrique Ma. Fernando - 13th Philippine Chief
Justice; 13th placer, 1938 Bar Exams (UP
College of Law)
Ramon Aquino - 15th Philippine Chief Justice;
9th placer, 1939 Bar Exams (UP College of Law)
Claudio Teehankee - 16th Philippine Chief
Justice; 1st placer, 1940 Bar Exams (Ateneo Law
School)
Pedro Yap - 17th Philippine Chief Justice; 1st
placer, 1946 Bar Exams (UP College of Law)
Andres Narvasa - 19th Philippine Chief Justice;
2nd placer, 1951 Bar Exams (UST Faculty of
Civil Law)
Artemio Panganiban - 21st Philippine Chief
Justice; 6th placer, 1960 Bar Exams (FEU
Institute of Law)
José P. Laurel - former Philippine Supreme
Court Justice; 2nd placer, 1915 Bar Exams
J. B. L. Reyes - former Philippine Supreme
Court Justice; 6th placer, 1922 Bar Exams
Cecilia Muñoz Palma - former Philippine Supreme
Court Justice; 1st placer, 1937 Bar Exams
Ambrosio Padilla - former Philippine Supreme
Court Justice; 3rd placer, 1934 Bar Exams
Ameurfina Melencio-Herrera - former Philippine
Supreme Court Justice; 1st placer, 1947 Bar
Exams
Irene Cortes - former Philippine Supreme Court
Justice; 9th placer, 1948 Bar Exams
Carolina A. Griño-Aquino - former Philippine
Supreme Court Justice; 1st placer, 1950 Bar
Exams
Isagani A. Cruz - former Philippine Supreme
Court Justice; 8th placer, 1951 Bar Exams
Rafael C. Climaco - former Philippine Court of
Appeals Justice; 5th placer, 1939 Bar Exams (
Ferdinand Marcos placed 1st )
Florentino Feliciano - former Philippine
Supreme Court Justice and Chair, WTO Appellate
Tribunal; 6th placer, 1952 Bar Exams
Florenz D. Regalado - former Philippine Supreme
Court Justice; 1st placer, 1954 Bar Exams
Adolfo Azcuna - Philippine Supreme Court
Justice; 4th placer, 1962 Bar Exams
Antonio Eduardo Nachura - Philippine Supreme
Court Justice; 7th placer, 1967 Bar Exams
Presbitero Velasco, Jr. - Philippine Supreme
Court Justice; 6th placer, 1971 Bar Exams
Antonio Carpio - Philippine Supreme Court
Justice; 6th placer, 1975 Bar Exams
Arturo D. Brion - Philippine Supreme Court
Justice; former Philippine Court of Appeals
Justice; 1st placer, 1974 Bar Exams
Bienvenido V. Reyes - former Philippine Court
of Appeals Presiding Justice; 5th placer, 1954
Bar Exams
Salome A. Montoya - former Philippine Court of
Appeals Presiding Justice; 6th placer, 1954 Bar
Exams
Alicia V. Sempio-Diy - former Philippine Court
of Appeals Justice; 5th placer, 1950 Bar Exams
Oscar M. Herrera - former Philippine Court of
Appeals Justice; 8th placer, 1953 Bar Exams
Demetrio Demetria - former Philippine Court of
Appeals Justice; 2nd placer, 1964 Bar Exams
Mario Guariña III - former Philippine Court of
Appeals Justice; 2nd placer, 1967 Bar Exams
Lucas Bersamin - Philippine Court of Appeals
Justice; 9th placer, 1973 Bar Exams
Celia Librea-Leagogo - Philippine Court of
Appeals Justice; 5th placer, 1981 Bar Exams
Only eleven of the 22 jurists who rose to become
Chief Justice of the Supreme Court were bar placers,
starting with José Yulo (3rd in 1913), followed by
Ricardo Paras (2nd in 1913), then by César Bengzon
(2nd in 1919), then by Roberto Concepcion (1st in
1924), then by Querube Makalintal (7th in 1933) then
by Enrique Fernando (13th in 1938), then by Ramon
Aquino (6th in 1939), then by Claudio Teehankee, Sr.
(1st in 1940), then by Pedro Yap (1st in November
1946), then by Andres Narvasa (2nd in 1951) and
finally by Artemio Panganiban (6th in 1960). However,
the first four chief magistrates (Cayetano Arellano,
Victorino Mapa, Manuel Araullo and Ramón Avanceña)
became lawyers (all after graduating from the UST
Faculty of Civil Law) before the establishment of the
Bar Exams in 1901 while the fifth head of the
judiciary (Jose Abad Santos) graduated from a foreign
law school and was admitted to the Philippine bar in
1911. Six Chief Justices did not place in the Bar
Exams: Manuel Moran (the father of Philippine
remedial law), Fred Ruiz Castro (the father of the
Integrated Bar of the Philippines), Felix Makasiar,
Marcelo Fernan, Hilario Davide and the incumbent
Reynato Puno).
Of the candidates to become the next Chief Justice
(to replace the retiring Reynato Puno) only two were
bar placers: Antonio Carpio (6th in 1975) of the UP
College of Law and Arturo Brion (1st in 1974) of the
Ateneo Law School. Both Carpio and Brion graduated
valedictorian of their respective law classes.
However, neither topnotcher made it to the apex of
the judicial summit, as Atenean Renato C. Corona was
appointed the chief magistrate.
Senators and Representatives
Manuel A. Roxas - former Philippine Senate
President and Speaker of the House of
Representatives; 1st placer, 1913 Bar Exams
Manuel L. Quezon - former Philippine Senate
President; 4th placer, 1903 Bar Exams
Arturo M. Tolentino - former Philippine Senate
President; 2nd placer, 1934 Bar Exams
Ferdinand E. Marcos - former Philippine Senate
President; 1st placer, 1939 Bar Exams
Jovito Salonga - former Philippine Senate
President; 1st placer, 1944 Bar Exams
Neptali Gonzales - former Philippine Senate
President; 9th placer, 1949 Bar Exams
Rodolfo Ganzon - former Philippine Senator and
Iloilo City Mayor; 2nd Placer, 1950 Bar Exams
Ernesto M. Maceda - former Philippine Senate
President; 10th placer, 1956 Bar Exams
Franklin M. Drilon - former Philippine Senate
President; 3rd placer, 1969 Bar Exams
Lorenzo Sumulong - former Philippine Senator;
1st placer, 1929 Bar Exams
Jose W. Diokno - former Philippine Senator; 1st
placer, 1944 Bar Exams
Renato V. Saguisag (Rene Saguisag) - former
Philippine Senator; 6th placer, 1963 Bar Exams
Aquilino Pimentel III (Koko Pimentel) -
Philippine Senator; 1st placer, 1990 Bar Exams
Sergio S. Osmeña - former Speaker of the House
of Representatives; 2nd placer, 1903 Bar Exams
Jose Y. Yulo - former Speaker of the House of
Representatives; 3rd placer, 1913 Bar Exams
Aguedo F. Agbayani - former Pangasinan
Representative; 5th placer, 1947 Bar Exams
Antonio Eduardo Nachura - former Samar
Representative; 7th placer, 1967 Bar Exams
Ronaldo B. Zamora - San Juan Representative;
1st placer, 1969 Bar Exams
Prospero Nograles - Speaker of the House of
Representatives; 2nd placer, 1971 Bar Exams
Arturo D. Brion - Assemblyman, Philippine
National Assembly; 1st placer, 1974 Bar Exams
Gilberto Eduardo Gerardo C. Teodoro, Jr. -
former Tarlac Representative; 1st placer, 1989
Bar Exams
José P. Laurel- former Senator; 2nd Placer 1915
Xavier Jesus Romualdo- incumbent Camiguin
Representative, 4th placer, 2012 Bar Exams
Of the lawyers who became President of the Senate,
only the following were bar placers: Manuel Quezon
(4th in 1903), Manuel Roxas (1st in 1913), Ferdinand
Marcos (1st in 1939), Arturo Tolentino (2nd in 1934),
Jovito Salonga (1st in 1944), Neptali Gonzales (9th
in 1949), Ernesto Maceda (10th in 1956), Franklin
Drilon (3rd in 1969) and Juan Ponce Enrile (11th in
1953). Of the incumbent senators with terms expiring
in 2013, five are lawyers (Ateneo Law School's Alan
Peter Cayetano as well as Edgardo Angara, Joker
Arroyo, Francis Escudero, and Francis Pangilinan of
the UP College of Law) and none of whom were previous
bar placers. Curiously, Aquilino Pimentel III of the
UP College of Law (who is contesting the seat
occupied by Sen. Juan Miguel Zubiri) placed 1st in
the 1990 Bar Exams.
On the other hand, of those who became Speaker of the
House of Representatives, only the following were bar
placers: Sergio Osmena, Sr. (2nd in 1903), Manuel
Roxas (1st in 1913), José Yulo (3rd in 1913) Querube
Makalintal (7th in 1933) and Prospero Nograles (2nd
in 1971). Of the chamber's other officers, only
Ronaldo Zamora was a former bar topnotcher (1st in
1969).
Curiously, the incumbent heads of both houses of
Congress were previous bar placers: Ateneo Law
School's Nograles for the lower house and UP College
of Law's Ponce Enrile for the upper house. After the
2010 elections, former Rep. Nograles (who did not run
for re-election) was replaced by lawyer Feliciano R.
Belmonte, Jr. (from Lyceum of the Philippines) as
Speaker. Sen. Enrile retained his post as Senate
President.
Appointees and career service officials
Roberto Concepcion - Member, 1986
Constitutional Commission; 1st placer, 1924 Bar
Exams
Lorenzo Sumulong - Member, 1986 Constitutional
Commission; 1st placer, 1929 Bar Exams
Arturo Tolentino - Member, Philippine Civil
Code Commission; former Minister of Foreign
Affairs; 2nd placer, 1934 Bar Exams
Ambrosio Padilla - Member, 1986 Constitutional
Commission; 3rd placer, 1934 Bar Exams
Diosdado Macapagal - President, Philippine
Constitutional Convention of 1971; 1st placer,
1936 Bar Exams
Cecilia Muñoz-Palma - President, Philippine
Constitutional Commission of 1986; Chairperson,
Philippine Charity Sweepstakes Office; 1st
placer, 1937 Bar Exams
Jovito Salonga - former Chairman, Presidential
Commission on Good Government; 1st placer, 1944
Bar Exams
Ameurfina Melencio-Herrera - Chancellor,
Philippine Judicial Academy; Chairperson, Legal
Publications Committee, Supreme Court Centenary
Celebrations; 1st placer, 1947 Bar Exams
Alicia V. Sempio-Dy - Member, Philippine Civil
Code Revision Committee; former Commissioner,
National Commission on Women; 5th placer, 1950
Bar Exams
Andres Narvasa - Chairman, Preparatory
Commission for Constitutional Reform; 2nd
placer, 1951 Bar Exams
Gabriel Singson - former Governor of the
Central Bank of the Philippines; 2nd placer,
1952 Bar Exams
Florentino Feliciano - Chairman, Feliciano
Commission investigating the Oakwood Mutiny;
6th placer, 1952 Bar Exams
Florenz D. Regalado - Member, 1986
Constitutional Commission; 1st placer, 1954 Bar
Exams
Jose Nolledo - Delegate, 1971 Constitutional
Convention & Member, 1986 Constitutional
Commission; 3rd placer, 1958 Bar Exams
Haydee Yorac - former Chairperson, Presidential
Commission on Good Government; former
Commissioner, Commission on Elections; 8th
placer, 1962 Bar Exams
Adolfo Azcuna - Member, 1986 Constitutional
Commission; 4th placer, 1962 Bar Exams
Joaquin G. Bernas - Member, 1986 Constitutional
Commission; Member, Feliciano Commission
investigating the Oakwood mutiny; 9th placer,
1962 Bar Exam
Anacleto C. Mañgaser (var. Mangaser) - former
Chairman, Reparations Commission; 1st placer,
1949 Bar Exams
Sergio A. Apostol - Chief Presidential Legal
Counsel; 7th placer, 1958 Bar Exams
Ismael G. Khan, Jr. - former Spokesperson,
Philippine Supreme Court; 6th placer, 1959 Bar
Exams
Antonio Eduardo Nachura - former Solicitor
General; 7th placer, 1967 Bar Exams
Fulgencio S. Factoran, Jr. - former Executive
Secretary; 9th placer, 1967 Bar Exams
Jose Mario Buñag - former Bureau of Internal
Revenue Commissioner; 2nd placer, 1968 Bar
Exams
Ronaldo B. Zamora - former Executive Secretary;
1st placer, 1969 Bar Exams
Gregorio Cabantac - former Undersecretary,
Department of Environment and Natural
Resources, 5th Placer, 1995 Bar Exams
Franklin Drilon - former Secretary of Labor and
Employment; 3rd placer, 1969 Bar Exams
Jess Dureza - Mindanao Super Region In-charge;
10th placer, 1973 Bar Exams
Arturo D. Brion - Secretary of Labor and
Employment; 1st placer, 1974 Bar Exams
Antonio Carpio - former Chief Presidential
Legal Counsel; 6th placer, 1975 Bar Exams
Avelino Cruz, Jr. - former Secretary of
National Defense; 7th placer, 1977 Bar Exams
Simeon Marcelo - former Philippine Ombudsman;
5th placer, 1979 Bar Exams
Manuel Antonio J. Teehankee - former
Undersecretary of Justice; Ambassador to the
World Trade Organization; 1st placer, 1983 Bar
Exams
Rabbi Elamparo Deloso - former Chief of Staff,
Philippine Senate, 16th Placer, 2000 Bar Exams
Antonio M. Bernardo - former Bureau of Customs
Commissioner; 2nd placer, 1988 Bar Exams
Gilberto Eduardo Gerardo C. Teodoro, Jr. -
Secretary of National Defense; 1st placer, 1989
Bar Exams
Persida V. Rueda-Acosta - Chief Public Attorney
of the Philippines; 5th placer, 1989 Bar Exams
Ruben Carranza, Jr. - Commissioner,
Presidential Commission on Good Government; 8th
placer, 1990 Bar Exams
Maria Celia H. Fernandez - former Chief,
Presidential Management Staff; 1st placer, 1997
Bar Exams
Janet B. Abuel - Asst.Secretary Dept. Of Budget
and Management; 1st placer, 1998 Bar Exams
Edwin R. Enrile - former Assistant Executive
Secretary, Office of the President; Deputy
Executive Secretary, Office of the President;
1st placer, 1999 Bar Exams
Rodolfo Ma. A. Ponferrada - former Assistant
Chief of Staff, Office of the Vice President;
1st placer, 2001 Bar Exams
Leila de Lima - current Secretary of Justice;
former Commission on Human Rights (CHR)
Chairperson; 8th placer, 1985 Bar Exams
Local officials
Pablo P. Garcia - former Governor of Cebu; 3rd
placer, 1951 Bar Exams
Aguedo F. Agbayani - former Governor of
Pangasinan; 5th placer, 1947 Bar Exams
Isidoro E. Real, Jr. - former Governor /
Congressman of Zamboanga del Sur; 7th placer,
1961 Bar Exams
Roldan Dalman - former Governor of Zamboanga
del Norte;former Presidential Assistant for
Regional Concerns, Western Mindanao 6th placer,
1975 Bar Exams
Douglas RA. Cagas - incumbent Governor / former
Congressman of Davao del Sur; 4th placer 1967
Bar Exams
Academe
Joaquin G. Bernas - former President, Ateneo de
Manila University; Dean Emeritus, Ateneo Law
School; 9th placer, 1962 Bar Exam
Jovito Salonga - former Dean, Far Eastern
University Institute of Law; 1st placer, 1944
Bar Exams
Neptali Gonzales - former Dean, Far Eastern
University Institute of Law; 9th placer, 1949
Bar Exams
Andres Narvasa - former Dean, University of
Santo Tomas Faculty of Civil Law; 2nd placer,
1951 Bar Exams
Norberto S. Gonzales - Dean, Manuel L. Quezon
University School of Law; 5th placer, 1958 Bar
Exams
Custodio O. Parlade - President Emeritus,
Philippine Dispute Resolution Centre; Lecturer
and Bar Reviewer; 4th placer, 1959 Bar Exams
Agustin O. Benitez - former Dean, University of
the East College of Law; 1st placer, 1959 bar
Exams
Virgilio B. Jara - Dean, San Beda College of
Law 5th placer, 1962 Bar Exams
Cesar L. Villanueva - Dean, Ateneo Law School;
2nd placer, 1981 Bar Exams
Jose Jesus G. Laurel - former Dean, Lyceum of
the Philippines College of Law; 6th placer,
1981 Bar Exams
Roy Joseph M. Rafols - former Dean, Palawan
State University College of Law; 2nd placer,
1984 Bar Exams
Pacifico N. Castro - Law Professor and Bar
Reviewer; 8th placer, 1954 Bar Exams
Manuel T. Muro - Law Professor and Bar
Reviewer, former Trial Court Judge; 6th placer,
1955 Bar Exams
Antonio H. Abad, Jr. - Law Professor and Bar
Reviewer; former Dean of the FEU Institute of
Law and presently Dean of the Adamson
University College of Law; 10th Placer, 1963
Bar Examinations
Roberto San Jose - Law Professor and Bar
Reviewer; 1st placer, 1966 Bar Exams
Ruben F. Balane - Law Professor and Bar
Reviewer; 2nd placer, 1966 Bar Exams
Hildegardo F. Iñigo - former Dean, Ateneo de
Davao University College of Law and Bar
Reviewer, 8th placer, 1966 Bar Exams
Jacinto D. Jimenez (Jack Jimenez) - Law
Professor and Bar Reviewer; 3rd placer, 1968
Bar Exams
Arturo de Castro - Law Professor and Bar
Reviewer; 3rd placer, 1970 Bar Exams
Rene Gorospe - Law Professor and Bar Reviewer;
2nd placer, 1979 Bar Exams
Manuel J. Laserna, Jr. - law professor and bar
reviewer (FEU, 1985-2006); 3rd placer, 1984 Bar
Examinations (90.95%)
Abelardo T. Domondon - Law Professor and Bar
Reviewer; 4th placer, 1985 Bar Exams, graduate
of Adamson University College of Law
Roberto A. Gana - Law Professor and Bar
Reviewer; 5th placer, 1986 Bar Exams
Jose Maria G. Hofileña - Law Professor and Bar
Reviewer; 10th placer, 1987 Bar Exams
Michael G. Aguinaldo - Law Professor; 7th
placer, 1992 Bar Exams
Anna Leah Fidelis T. Castañeda - Law Professor;
1st placer, 1993 Bar Exams
Shirley F. Alinea UP Law (6th Place, 1996 Bar
Exams) - Law Professor (UE, Lyceum, San
Sebastian)
Rabbi Elamparo Deloso - Law Professor, FEU
Institute of Law, University of Bristol School
of Law Lecturer; 16th placer, 2000 Bar Exams
Maria Socorro Z. Manguiat - Law Professor; 10th
placer, 1993 Bar Exams
Ralph A. Sarmiento - Dean, University of St. La
Salle College of Law; International Law Bar
Reviewer; 10th placer, 1997 Bar Exams
Shennan A. Sy - Law Professor; 6th placer, 1995
Bar Exams
Arnold De Vera - Law Professor; 8th placer,
1987 Bar Exams
Rhett Emmanuel C. Serfino - Practicing Lawyer;
Professor and Bar Reviewer (MLQU, PUP,
Universidad De Manila); 3rd placer, 1997 Bar
Exams
Florin T. Hilbay - Law Professor; 1st placer,
1999 Bar Exams
Rodolfo Ma. A. Ponferrada - Professor of Law
(UP and Ateneo); 1st placer, 2001 Bar Exams
Solomon F. Lumba - Professor of Law (UP); 4th
placer, 2001 Bar Exams
Adonis V. Gabriel - Professor of Law (SBC); 8th
placer, 2001 Bar Exams
Samson S. Alcantara - Practicing Lawyer;
Professor and Bar Reviewer (MLQU); Author-
Philippine Labor and Social Legislation; 3rd
placer, Bar Exams
Connie Chu - Professor(Ateneo), 2nd Place, 2002
Bar Exams
Ma. Ngina Chan-Gonzaga - Professor(Ateneo), 4th
Place, 2002 Bar Exams
Michelle Juan - Professor(Ateneo, FEU-DLSU,
PLM), 4th Place, 2002 Bar Exams
Nyerson Dexter Tito Q. Tualla - Corporate
Attorney, TransCo; Civil Law Lecturer, Manuel
L. Quezon University; 4th placer, 2005 Bar
Exams
Pedro Jose F. Bernardo - Professor (Ateneo,
FEU-DLSU, PLP), 8th Place, 2005 Bar Exams
Noel Neil Q. Malimban - Business Law Lecturer
and Reviewer, University of the Cordilleras;
1st placer, 2006 Bar Exams
Guillermo A. Villasor, Jr. - former Dean,
University of Negros Occidental - Recoletos
School of Law; 10th placer,1979 Bar Exams
Marforth T. Fua - Law Professor (SBC, PLP), 8th
place, 2007 Bar Exams
Reinier Paul R. Yebra - Professor, San Beda
College of Law; 1st placer, 2009 Bar Exams
Teodoro Almase - Dean, University of the
Visayas, 4th place
Private sector
Manuel Montecillo - Name Partner, Siguion Reyna
Montecillo & Ongsiako (oldest law firm); 1st
placer, 1948 Bar Exams
Manuel S. Abello - Founding Partner, Angara
Abello Concepcion Regala & Cruz (ACCRALAW) ;
1st placer, 1958 Bar Exams
Nelly Favis-Villafuerte - Editor, Manila
Bulletin; 7th placer, 1959 Bar Exams
Avelino V. Cruz - Founding Partner, ACCRALAW;
youngest to top the bar, 1st placer, 1962 Bar
Exams
Mercedita V. Santiago-Nolledo - Corporate
Secretary, Ayala Corporation; 2nd placer, 1965
Bar Exams
Rodolfo D. Robles - General practitioner; 1st
placer, 1967 Bar Exams
Leonor Dicdican - Associate, Gordon & Reese Law
Firm, California; 1st placer, 1996 Bar Exams
Januario B. Soller, Jr. - Co-founder, Soller
Chain of Pawnshops; 1st placer, 1972 Bar Exams
Jesus M. Manalastas - Name Partner, PECABAR Law
Firm; 2nd placer, 1972 Bar Exams
Victor P. Lazatin - Senior Partner, ACCRALAW;
3rd placer, 1972 Bar Exams
Barbara Anne Migallos - Name Partner, Roco
Buñag Kapunan Migallos Law Firm; Co-founder,
Migallos & Luna Law Office; 3rd placer, 1979
Bar Exams
Mario Luz Bautista - Co-founder, Poblador
Bautista Reyes Law Firm; 6th placer, 1979 Bar
Exams
Arthur Lim - former National President,
Integrated Bar of the Philippines; 3rd placer,
1981 Bar Exams
Ray C. Espinosa - Partner, SyCip Salazar
Hernandez & Gatmaitan; Executive Director,
Philippine Long Distance Telephone Company;
President and CEO, ePLDT; President and CEO,
Associated Broadcasting Corporation; Vice
Chairman, Philweb Corporation; 1st placer, 1982
Bar Exams
Agerico T. Paras - Founding Partner and
Managing Partner, Paras and Manlapaz Lawyers;
6th placer, 1983 Bar Exams
Menardo L. Guevarra - Co-founder, Serapio
Guevarra Medialdea Law Firm; 2nd placer, 1985
Bar Exams
Marlon Manuel - Director, SALIGAN (non-profit
legal assistance group); 5th placer, 1994 Bar
Exams
Patricia-ann T. Prodigalidad - Partner,
ACCRALAW; 1st placer, 1996 Bar Exams
Maria Celia H. Fernandez - In-house counsel,
Yuchengco group of companies; 1st placer, 1997
Bar Exams
Jose Raulito E. Paras - Partner, Andres Marcelo
Padernal Guerrero & Paras; 5th placer, 1997 Bar
Exams
Eliseo M. Zuñiga, Jr. - Partner, Quisumbing
Torres Law Firm; 1st placer, 2000 Bar Exams
Valerie Feria Amante- Legal Division Head,
Jollibee Group of Companies; 7th placer, 2000
Bar Exams
Rodolfo Ma. A. Ponferrada - Associate, SyCip
Salazar Hernandez & Gatmaitan; 1st placer, 2001
Bar Exams
Ma. Theresa U. Ballelos - Associate, Quisumbing
Torres Law Firm; 6th placer, 2001 Bar Exams
Arlene Maneja - Associate, Siguion Reyna
Montecillo & Ongsiako; 1st placer, 2002 Bar
Exams
Aeneas Eli S. Diaz - Associate, Villaraza &
Angangco; 1st placer, 2003 Bar Exams
January A. Sanchez - Consultant, Asian
Development Bank; 1st placer, 2004 Bar Exams
Joan A. De Venecia - Associate, SyCip Salazar
Hernandez & Gatmaitan; 1st placer, 2005 Bar
Exams
Noel Neil Q. Malimban - Associate, Castillo
Laman Tan Pantaleon & San Jose; 1st placer,
2006 Bar Exams
Reinier Paul R. Yebra - Associate, ACCRALAW;
1st placer, 2009 Bar Exams
Cesareo Antonio S. Singzon Jr. - Associate,
ACCRALAW; 1st placer, 2010 Bar Exams
Filemon Ray L. Javier - Associate, ACCRALAW;
2nd placer, 2010 Bar Exams
1st place in the Philippine Bar Examinations
Name Year School Hometown
Epifanio de los
Santos y
Cristobal [53]
1898 University of
Santo Tomas
Malabon,
Rizal
1899
1900
1901
1902
1903
1904
1905
1906
1907
1908
1909
1910
1911
1912
Manuel Roxas 1913 University of the
Philippines
Roxas City,
Capiz
Manuel Goyena 1914 University of the
Philippines
Francisco
Villanueva
1915 University of the
Philippines
Paulino Gullas 1916 University of the
Philippines
Felipe Ismael 1917 University of the
Philippines
Alejo Labrador 1918 University of the
Philippines
San Narciso,
Zambales
Gregorio Anonas 1919 Philippine Law
School
Adolfo
Brillantes
1920 Escuela de Derecha
Pablo C.
Payawal
1921 University of the
Philippines
Amando L.
Velila
1922 University of the
Philippines
Roque
Desquitado
1923 University of the
Philippines
Roberto
Concepcion
1924 University of
Santo Tomas
Manila
Rafael
Dinglasan
1925 University of the
Philippines
Eugeniano Perez 1926 Philippine Law
School
Cesar Kintanar 1927 University of the
Philippines
Filomeno B.
Pascual
1928 Philippine Law
School
Lorenzo
Sumulong
1929 University of the
Philippines
Antipolo City
Tecla San
Andres
1930 University of the
Philippines
Jose Leuterio 1931 University of the
Philippines
Hermenegildo
Atienza
1932 University of the
Philippines
Lope C. Quimbo 1933 University of
Manila
Catbalogan,
Samar
Marciano Catral 1934 Philippine Law
School
Enrique
Estrellado
1935 University of the
Philippines
Diosdado
Macapagal
1936 University of
Santo Tomas
Lubao,
Pampanga
Cecilia Muñoz-
Palma
1937 University of the
Philippines
Bauan,
Batangas
Emmanuel Pelaez 1938 University of
Manila
Medina,
Misamis
Oriental
Ferdinand
Marcos
1939 University of the
Philippines
Sarrat,
Ilocos Norte
Claudio
Teehankee
1940 Ateneo de Manila
University
Manila
Emmet P.D. Shea 1941 University of the
Philippines
1942
1943
Jovito Salonga
1944
University of the
Philippines
Pasig, Rizal
Jose Diokno
Special
(University of
Santo Tomas)
Gregoria Cruz 1945 University of the
Philippines
Pedro Yap 1946 University of the
Philippines
San Isidro,
Leyte
Ameurfina
Melencio-
Herrera
1947 University of the
Philippines
Manuel
Montecillo
1948 Far Eastern
University
Candelaria,
Quezon
Anacleto C.
Mañgaser
1949 Philippine Law
School
Caba, La
Union
Carolina A.
Griño-Aquino
1950
Special (Colegio
de San Agustin,
University of the
Philippines)
Capiz
Vicente R.
Acsay
1951 University of
Manila
Pedro Samson C.
Animas
1952 University of the
Philippines
Leonardo A.
Amores
1953 University of
Manila
Florenz D.
Regalado
1954 San Beda College
Concepcion,
Iloilo
Tomas P. Matic,
Jr.
1955 Far Eastern
University
Francisco C. 1956 San Beda College
Catral
Gregorio R.
Castillo
1957 University of the
Philippines
Manuel G.
Abello
1958 University of the
Philippines
Agustin O.
Benitez
1959 Far Eastern
University
Ismael Andres 1960 Manuel L. Quezon
University
Avelino V. Cruz 1961 San Beda College
Deogracias G.
Eufemio
1962 University of the
Philippines
Cornelio C.
Gison
1963 Ateneo de Manila
University
Jesus P.
Castelo
1964 San Beda College
Victor S. de la
Serna
1965 San Beda College
Tagbilaran
City, Bohol
Roberto San
Jose
1966 University of the
Philippines
Rodolfo D.
Robles
1967 San Beda College
Oscar B.
Glovasa
1968
Divine Word
College of
Tagbilaran
Tagbilaran
City, Bohol
Ronaldo B.
Zamora
1969 University of the
Philippines
Romulo D. San
Juan
1970 University of the
Philippines
Henry R.
Villarica
1971 University of the
Philippines
Januario B.
Soller, Jr.
1972 Ateneo de Manila
University
Vicente R. 1973 Ateneo de Manila Zamboanga
Solis University City
Arturo D. Brion 1974 Ateneo de Manila
University
Manila
Nicanor B.
Padilla, Jr.
1975 University of the
East
Enrique
Teehankee
1976 University of the
Philippines
Virgilio B.
Gesmundo
1977 Ateneo de Manila
University
Cosme D. Rosell 1978 University of the
Philippines
Gregorio M.
Batiller, Jr.
1979 Ateneo de Manila
University
Rafael R. Lagos 1980 University of the
Philippines
Irene Ragodon-
Guevarra
1981 Ateneo de Manila
University
Ray C. Espinosa 1982 Ateneo de Manila
University
Manuel Antonio
J. Teehankee
1983 Ateneo de Manila
University
Richard M. Chiu 1984 Ateneo de Manila
University
Dumaguete
City, Negros
Oriental
Janette Susan
L. Peña
1985 University of the
Philippines
Laurence L. Go 1986 Ateneo de Manila
University
Mario P.
Victoriano
1987 Ateneo de Manila
University
Maria Yvette O.
Navarro
1988 University of the
Philippines
Gilberto
Teodoro, Jr.
1989 University of the
Philippines
Aquilino
Pimentel III
1990 University of the
Philippines
Cagayan de
Oro City
Joseph P. San
Pedro
1991 Ateneo de Manila
University
Jayme A. Sy,
Jr.
1992 Ateneo de Manila
University
Anna Leah
Fidelis T.
Castañeda
1993 Ateneo de Manila
University
Francisco Noel
R. Fernandez
1994 University of the
Philippines
Cebu City
Leonor Y.
Dicdican
1995 University of the
Philippines
Cebu City
Patrcia-ann T.
Progalidad
1996 University of the
Philippines
Ma. Cecilia H.
Fernandez
1997 University of the
Philippines
Janet B. Abuel 1998 University of the
Cordilleras
Florin Hilbay
1999
University of the
Philippines
Edwin R. Enrile
Ateneo de Manila
University
Naga City,
Camarines Sur
Eliseo M.
Zuñiga, Jr.
2000 University of the
Philippines
Rodolfo Ma. A.
Ponferrada
2001 University of the
Philippines
Arlene Maneja 2002 University of
Santo Tomas
Aeneas Eli S.
Diaz
2003 Ateneo de Manila
University
January A.
Sanchez
2004 University of the
Philippines
Joan A. De 2005 University of the
Venecia Philippines
Noel Neil Q.
Malimban
2006 University of the
Cordilleras
Mercedita L.
Ona
2007 Ateneo de Manila
University
Judy A.
Lardizabal
2008
San Sebastian
College -
Recoletos
Imus, Cavite
Reinier Paul
Yebra
2009 San Beda College
Cesareo Antonio
Singzon, Jr.
2010 Ateneo de Manila
University
Catbalogan,
Samar
Raoul Angelo
Atadero
2011 Ateneo de Manila
University
Meycauayan
City, Bulacan
Ignatius
Michaeal D.
Ingles
2012 Ateneo de Manila
University
Nielson G.
Pangan 2013
University of the
Philippines