Pimentel v. Legal Education Board [G.R. Nos. 230642 & 242954, September 10, 2019]

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Pimentel v. Legal Education Board

 G.R. Nos. 230642 & 242954, [September 10, 2019]

EN BANC, REYES J.

 

Academic Freedom of Educational Institution 

The Court struck down the specific provisions of PhiLSAT and faculty qualification requirements that it deemed unconstitutional. The strict pass-fail requirement of PhiLSAT and the faculty qualification requirements went beyond reasonable regulation and intruded on academic freedom. LEB’s regulatory power should be reasonable and should not unduly restrict the autonomy of educational institutions and the choices of students.

This case involves consolidated petitions challenging the constitutionality of Republic Act No. 7662, known as the Legal Education Reform Act of 1993. The act established the Legal Education Board (LEB) and introduced the Philippine Law School Admission Test (PhiLSAT) as a requirement for law school applicants. Petitioners primarily argued that these provisions violated academic freedom.

 

Whether the introduction of PhiLSAT and related provisions under R.A. No. 7662 infringe upon the academic freedom of law schools and applicants.

  

Yes. The Supreme Court held that R.A. No. 7662 did not encroach upon the Court's rule-making authority and that the state had the jurisdiction to regulate legal education in the interest of public welfare. However, certain provisions of PhiLSAT that excluded, restricted, and qualified admissions to law schools were deemed unconstitutional as they violated institutional academic freedom.

The Court found that the PhiLSAT, in its current form, impeded academic freedom by restricting law schools' discretion in admissions and, therefore, ruled certain PhiLSAT provisions unconstitutional. The Court also nullified certain LEB issuances that exceeded the powers granted under its charter. The Court upheld the jurisdiction of the Legal Education Board over legal education but with limitations to protect academic freedom of educational institutions. 

 

Violation of Academic Freedom: 

·        Interference with Admission Policies: The Court reasoned that PhiLSAT, as initially designed, imposed a pass-or-fail requirement for law school admission. This meant that law schools were restricted in admitting students solely based on their PhiLSAT scores. 

·        Restriction on Student Choice: academic freedom extends to students as well. The PhiLSAT, by imposing a rigid entrance exam requirement, limited the students' ability to choose their preferred law schools. 

·        Faculty Qualification Requirements: The law required that law professors have at least five years of practice or substantial experience in the field before they could teach. The Court found that this provision could limit the pool of qualified professors and limit the academic freedom of law schools to choose their faculty members.

 

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