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Mindanao university ordered to close law programs

  The Legal Education Board (LEB) has ordered the Mindanao State University to close its law programs in all its campuses starting academic year 2025-2026 after it approved a resolution canceling MSU’s accreditation. The order stemmed from MSU’s refusal to recognize LEB’s supervisory authority and for asserting that it is not bound by the board’s orders, policies and guidelines on legal education. “The MSU is no longer authorized to offer the basic law program in the country,”  the LEB said. The board made permanent the cease and desist order it issued against MSU’s extension law programs on its campuses in Tawi-Tawi, Sulu and Maguindanao. It expressed concern over what it described as MSU’s “dismal” performance in the Bar examinations, noting the school’s passing rate since 2013 has been below the national passing percentage. Reacting to the LEB’s resolution, the MSU said it would continue to operate in accordance with its chapter passed by Congress in 1955. “The LEB cannot act no

The SC upholds the constitutionality of the IBP.

The SC upholds the constitutionality of the IBP. 


The practice of law is not a natural, property or constitutional right but a mere privilege, a privilege clothed with public interest because a lawyer owes substantial duties not only to his client, but also to his brethren in the profession, to the courts, to the nation, and takes part in one of the most important functions of the State, the administration of justice, as an officer of the court. 

[...] even without the enabling Act (Republic Act No. 6397), and looking solely to the language of the provision of the Constitution granting the Supreme Court the power 

"to promulgate rules concerning pleading, practice and procedure in all courts, and the admission to the practice of law,"

 it at once becomes indubitable that this constitutional declaration vests the Supreme Court with plenary power in all cases regarding the admission to and supervision of the practice of law. 

The first objection posed by the respondent is that the Court is without power to compel him to become a member of the Integrated Bar of the Philippines, hence, Section 1 of the Court Rule is unconstitutional for it impinges on his constitutional right of freedom to associate (and not to associate). 


Our answer is: To compel a lawyer to be a member of the Integrated Bar is not violative of his constitutional freedom to associate. 

Integration does not make a lawyer a member of any group of which he is not already a member. He became a member of the Bar when he passed the Bar examinations.  All that integration actually does is to provide an official national organization for the well-defined but unorganized and incohesive group of which every lawyer is a ready a member. 

Bar integration does not compel the lawyer to associate with anyone. He is free to attend or not attend the meetings of his Integrated Bar Chapter or vote or refuse to vote in its elections as he chooses. The only compulsion to which he is subjected is the payment of annual dues. The Supreme Court, in order to further the State's legitimate interest in elevating the quality of professional legal services, may require that the cost of improving the profession in this fashion be shared by the subjects and beneficiaries of the regulatory program — the lawyers 

Assuming that the questioned provision does in a sense compel a lawyer to be a member of the Integrated Bar, such compulsion is justified as an exercise of the police power of the State. 

[...] Thus, when the respondent Edillon entered upon the legal profession, his practice of law and his exercise of the said profession, which affect the society at large, were (and are) subject to the power of the body politic to require him to conform to such regulations as might be established by the proper authorities for the common good, even to the extent of interfering with some of his liberties. If he did not wish to submit himself to such reasonable interference and regulation, he should not have clothed the public with an interest in his concerns.

(In Re: IBP Membership Dues Delinquency of Atty. Marcial A. Edillon, A.M. No. 1928, August 3, 1978). 



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