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 𝘗𝘦𝘳 𝘊𝘶𝘳𝘪𝘢𝘮 Decision, the SC 𝘌𝘯 𝘉𝘢𝘯𝘤 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 𝘛𝘴𝘪𝘥𝘬𝘦𝘯𝘶 𝘋𝘪𝘻𝘰𝘯 claimed that the 2023 Bar Examinations would be “𝘴𝘰𝘳𝘵𝘦𝘥, 𝘤𝘩𝘦𝘤𝘬𝘦𝘥, 𝘢𝘯𝘥 𝘤𝘰𝘳𝘳𝘦𝘤𝘵𝘦𝘥 𝘣𝘺 𝘮𝘦𝘢𝘯𝘴 𝘰𝘧 𝘢𝘳𝘵𝘪𝘧𝘪𝘤𝘪𝘢𝘭 𝘪𝘯𝘵𝘦𝘭𝘭𝘪𝘨𝘦𝘯𝘤𝘦 (𝘈𝘐).” It also stated:
“𝘈𝘓𝘞𝘈𝘠𝘚 𝘚𝘛𝘈𝘙𝘛 𝘞𝘐𝘛𝘏 𝘠𝘌𝘚 𝘰𝘳 𝘕𝘖.
𝘠𝘢𝘯 𝘢𝘯𝘨 𝘶𝘯𝘢𝘯𝘨 𝘩𝘢𝘩𝘢𝘯𝘢𝘱𝘪𝘯 𝘯𝘨 𝘈𝘐 𝘊𝘩𝘦𝘤𝘬𝘪𝘯𝘨 𝘵𝘰 𝘴𝘰𝘳𝘵 𝘰𝘶𝘵 𝘵𝘩𝘦 𝘤𝘰𝘳𝘳𝘦𝘤𝘵 𝘢𝘯𝘴𝘸𝘦𝘳𝘴.”
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 “within 24 hours”, in a media interview. He also sent several emails to the SC’s 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 “TO HELP” in his post.
The SC was not convinced and held him liable under Rule 71, Section 3 of the 𝘙𝘶𝘭𝘦𝘴 𝘰𝘧 𝘊𝘰𝘶𝘳𝘵, 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 Dizon’s 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 Dizon’s 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 𝘉𝘢𝘳 𝘓𝘢𝘸 𝘧𝘰𝘳 𝘋𝘶𝘮𝘮𝘪𝘦𝘴 training program. Dizon acknowledged that while he had passed the 2016 Bar Examinations, he had not taken the lawyer’s 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 Court’s 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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