Bar topnotchers in the Philippines 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.[1]
Overview
From 1913 to 2019, schools which have produced bar topnotchers (1st placers) are as follows:[1]
Two bar examinees topped the bar exams without officially graduating from any Philippine law school:[1]
Jose W. Diokno – former Senator of the Philippines; 1st placer, 1945 bar exams. Diokno Sr., who tied for Number One with former Senate President 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[2] and that he also placed number 1 in the 1940 CPA Board exams which he took while in law school, summa cum laude[3] after graduating from then De La Salle College[4] 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 and Reginald Laco (from the De La Salle Lipa Law School) who placed fourth in the 2015 Bar Exams and second in the 2009 CPA Board Exams.[5]
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.[2] Both spouses Aquino (in addition to being topnotchers) also served as Justices of the Supreme Court.[6]
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.[7]
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.[1] 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 San Beda College[8] of Law's sole magna cum laude graduate, Florenz Regalado,[9][10] 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.[1] 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 became Minority Leader in the House of Representatives.
Bar Topnotchers List
The Office of the Bar Confidant releases an official Bar Topnotchers 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.[11]
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.[11]
Below is a listing of all 106 first-placers (from 1913 to 2019) and can be rearranged from highest to lowest in terms of rating obtained. Bar ratings are not exactly comparable from year-to-year as the difficulty of the exams varies through the years. Two bar examinations took place in 1946, first in August to cover the absence of the examination the previous year and in November for the present year. There was a tie in first place in two occasions – in 1944 and in 1999.
^1 Due to the ongoing COVID-19 pandemic, the Supreme Court En banc instituted bar reforms pro hac vice in conducting the 2020-2021 bar examinations, including:
Digitization and regionalization of the bar examinations.[15]
Postponement of the bar examination to February 4, 2022, and February 6, 2022.[16]
Reduction of Bar Coverage to 4 subjects - Laws pertaining to the State and Its relationship with its Citizens (formerly Political Law, Labor Law, and Taxation Law); Criminal Law; Law pertaining to Private Personal and Commercial Relations (formerly Civil Law and Commercial law); and Procedure and Professional Ethics (formerly Remedial Law, Legal Ethics and Practical Exercises).[17]
^2 Declaration of bar topnotchers is suspended. Examinees who obtain 85% or higher shall be recognized for exemplary performance.[18]
Highest and lowest topnotcher grades
Jose Hontiveros obtained an average of 98% in 1911.[19] 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 bachelor's degree in law, earning it in 1946. The only other instance of a tie at the first place in 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.[2] Atty. Hilbay served as the Solicitor General from 2014 to 2016 and is the current dean of the Siliman University College of Law.[20] 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.
The lowest grade was obtained by Ateneo Law School's Mercedita L. Ona, 83.55%, 2007, 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.[1][21] Atty. Ona was just the latest of women's 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.
Arturo M. Tolentino – former vice president of the Philippines; 2nd placer, 1934 Bar Exams (UP)
Supreme Court and Court of Appeals Justices
Jose Hontiveros - Associate Justice of the First Supreme Court; Associate Justice of the Court of Appeals; 1st placer, 1911 Bar Exams (University of Santo Tomas)
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 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
Ambrosio Padilla – former Philippine Supreme Court Justice; 3rd placer, 1934 Bar Exams
Cecilia Muñoz-Palma – former Philippine Supreme Court Justice; 1st placer, 1937 Bar Exams
Leila de Lima – current Philippine Senator; former Secretary of Justice; former Commission on Human Rights (CHR) Chairperson; 8th placer, 1985 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
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
