11/09/2026
The (SC) has found a bar review coach guilty of indirect contempt for spreading false information about the 2023 Bar Examinations on Facebook after stating that the said exams would be checked by means of artificial intelligence (AI).
In a ๐๐ฆ๐ณ ๐๐ถ๐ณ๐ช๐ข๐ฎ Decision, the SC ๐๐ฏ ๐๐ข๐ฏ๐ค found Edgar S. Dizon, administrator of the Facebook group Bar Law for Dummies, liable for indirect contempt. The Court fined him PHP 30,000 and ordered the removal of his name from the list of 2016 Bar passers.
On September 21, 2023, a post from the Facebook group and the account ๐๐ด๐ช๐ฅ๐ฌ๐ฆ๐ฏ๐ถ ๐๐ช๐ป๐ฐ๐ฏ claimed that the 2023 Bar Examinations would be โ๐ด๐ฐ๐ณ๐ต๐ฆ๐ฅ, ๐ค๐ฉ๐ฆ๐ค๐ฌ๐ฆ๐ฅ, ๐ข๐ฏ๐ฅ ๐ค๐ฐ๐ณ๐ณ๐ฆ๐ค๐ต๐ฆ๐ฅ ๐ฃ๐บ ๐ฎ๐ฆ๐ข๐ฏ๐ด ๐ฐ๐ง ๐ข๐ณ๐ต๐ช๐ง๐ช๐ค๐ช๐ข๐ญ ๐ช๐ฏ๐ต๐ฆ๐ญ๐ญ๐ช๐จ๐ฆ๐ฏ๐ค๐ฆ (๐๐).โ It also stated:
โ๐๐๐๐๐ ๐ ๐๐๐๐๐ ๐๐๐๐ ๐ ๐๐ ๐ฐ๐ณ ๐๐.
๐ ๐ข๐ฏ ๐ข๐ฏ๐จ ๐ถ๐ฏ๐ข๐ฏ๐จ ๐ฉ๐ข๐ฉ๐ข๐ฏ๐ข๐ฑ๐ช๐ฏ ๐ฏ๐จ ๐๐ ๐๐ฉ๐ฆ๐ค๐ฌ๐ช๐ฏ๐จ ๐ต๐ฐ ๐ด๐ฐ๐ณ๐ต ๐ฐ๐ถ๐ต ๐ต๐ฉ๐ฆ ๐ค๐ฐ๐ณ๐ณ๐ฆ๐ค๐ต ๐ข๐ฏ๐ด๐ธ๐ฆ๐ณ๐ด.โ
As a result, the Office of the 2023 Bar Chair (BCO), headed by Associate Justice Ramon Paul L. Hernando, had to investigate the source of the post and determine its impact on the examinations. It also issued an advisory clarifying that the examinations would be checked by four human examiners for each subject, all of whom are experts in their respective fields.
But instead of removing the post, Dizon threatened to sue the Court and demanded a public apology โwithin 24 hoursโ, in a media interview. He also sent several emails to the SCโs Judiciary Public Assistance Section, claiming that the advisory had a chilling effect on him. He denied spreading misinformation and asked the Court to issue a statement correcting the advisory.
After being directed by the SC to explain why he should not be cited for indirect contempt for interfering with the conduct of the 2023 Bar Examinations, Dizon admitted owning the Facebook account but denied claiming that AI would check the examinations, arguing that he used the words โTO HELPโ in his post.
The SC was not convinced and held him liable under Rule 71, Section 3 of the ๐๐ถ๐ญ๐ฆ๐ด ๐ฐ๐ง ๐๐ฐ๐ถ๐ณ๐ต, which punishes unlawful interference with court processes outside a courtroom, conduct that degrades the courts or undermines public confidence in the administration of justice, and unauthorized practice of law, as indirect contempt.
The SC held that Dizonโs post unlawfully interfered with the conduct of the 2023 Bar Examinations and undermined the integrity of both the exams and the SC, which exercises supervision over the legal profession. It caused confusion and alarm, forcing bar officials to divert their limited time and resources to tracing the source of the post, coordinating with government agencies, issuing clarifications, and responding to numerous inquiries.
The SC further noted Dizonโs lack of remorse. Instead of acknowledging the harm caused by his post, he demanded an apology from the Court, threatened legal action, refused to take down the post, and sought a statement retracting the advisory.
The Court likewise warned Dizon from engaging in the unauthorized practice of law when he conducted bar review coaching sessions and authored several bar review materials used in the ๐๐ข๐ณ ๐๐ข๐ธ ๐ง๐ฐ๐ณ ๐๐ถ๐ฎ๐ฎ๐ช๐ฆ๐ด training program. Dizon acknowledged that while he had passed the 2016 Bar Examinations, he had not taken the lawyerโs oath, which is one of the requirements to practice law, because of pending criminal cases.
In his Separate Concurring Opinion, Senior Associate Justice Marvic M.V.F. Leonen agreed that Dizon must be punished for undermining the integrity of the Bar examinations. However, he also emphasized the need to balance the Courtโs power to punish for contempt with the constitutional right to free speech, including legitimate criticism of the courts.
Read the full text of the press release at https://sc.judiciary.gov.ph/?p=172950
Read the full text of the Decision at https://sc.judiciary.gov.ph/4734-in-re-social-media-posts-of-edgar-s-dizon/
Read the Separate Concurring Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/4734-separate-concurring-opinion-senior-associate-justice-marvic-m-v-f-leonen/
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