The Supreme Court found Edgar S. Dizon guilty of indirect contempt and ordered him to pay a fine of PHP 30,000.00 over a false social media post claiming the 2023 Bar Examinations would be sorted, checked, and corrected by means of artificial intelligence. The Court also directed the Office of the Bar Confidant to delist Dizon from the list of bar passers.
The Case
A post originating from the Facebook accounts of Bar Law for Dummies and Tsidkenu Dizon surfaced on September 21, 2023, claiming, among others, that the 2023 Bar Examinations shall be sorted, checked, and corrected by means of artificial intelligence (AI). The posts went viral on social media and caused further panic and anxiety to the examinees, who were then in the middle of their final preparations.
The post disrupted the bar operations as the Office of the 2023 Bar Chair had to track down its origin and authorship and assess its impact on the bar examinees. The Office of the 2023 Bar Chair issued an Advisory condemning the publications as false, baseless, irresponsible, defamatory, contumacious, detestable, and formulated with apparent intent to erode the integrity of the digitalized Bar Examinations. The Advisory stated that the 2023 Bar Examinations shall be checked by four examiners per subject, all established experts who are by no means created or powered by artificial intelligence.
The administrator of both Facebook accounts was later unveiled to be a certain Edgar S. Dizon. Instead of taking down the posts, Dizon sought the attention of the media for an interview, threatened the Court with a suit, and demanded a public apology within 24 hours from the airing of his interview. Dizon also sent several e-mails to the Judiciary Public Assistance Section.
In a Resolution dated October 24, 2023, the Court required Dizon to show cause why he should not be cited for indirect contempt under Sections 3(c), (d), and (e), Rule 71 of the Rules of Court. In his Explanation, Dizon admitted he is the account holder of Bar Law for Dummies Training Program and Tsidkenu Dizon. He graduated from Arellano School of Law in 2016 and passed the Bar Examinations the same year but failed to take the oath because of pending murder cases. He insisted he did not say the AI would do the sorting, checking, or correction, and denied engaging in the practice of law.
The Issue
The issue that confronted the Court was whether Dizon should be held liable for indirect contempt.
The Ruling
The Court ruled in the affirmative. It held that Dizon's preparation of various bar review materials required the application of legal knowledge, so there can be no conclusion other than that Dizon illegally engaged in the practice of law, making him similarly guilty of indirect contempt.
In its dispositive portion, the Court ordered: "FOR THESE REASONS, Edgar S. Dizon is found GUILTY of indirect contempt and is directed to PAY a FINE of PHP 30,000.00. The Office of the Bar Confidant is DIRECTED to DELIST Edgar S. Dizon from the list of bar passers and to make a report thereon to the Court within five days from notice. Dizon is WARNED from further engaging in the unauthorized practice of law."
By the Numbers
- September 21, 2023 — the post surfaced on the Facebook accounts
- October 24, 2023 — Resolution requiring Dizon to show cause
- 24 hours — period within which Dizon demanded an apology from the Court
- 4 examiners per subject checking the 2023 Bar Examinations
- 2016 — year Dizon graduated and passed the Bar Examinations
- PHP 30,000.00 — fine imposed on Dizon
- Five days — period for the Office of the Bar Confidant to report
The Court's Reasoning
The Court noted that Dizon did not express any remorse in disrupting and degrading the 2023 Bar Examinations. On the contrary, he manifested excessive audacity by demanding an apology from the Court within 24 hours, threatening the Court with a suit, and refusing to take down his posts despite being aware that they caused unnecessary panic among the examinees.
The Court underscored the importance of maintaining the people's trust in the Judiciary. It explained that fair criticism of a court's rulings is not improper, but when critics charge that judicial conduct was influenced by improper, corrupt, or selfish motives, the tendency is to create distrust and destroy the confidence of the people in their courts.
Under Rule 71, Section 7, indirect contempt may be punished by a fine not exceeding PHP 30,000.00 or imprisonment not exceeding six months, or both, if committed against a Regional Trial Court or a court of equivalent or higher rank. The Court found the imposition of a PHP 30,000.00 fine appropriate.
The Court further explained that it is the gatekeeper to the bar and that the practice of law is a privilege and not a vested right. Citing the 2025 Proposed Amendments to Rule 138, the Court noted that preventive measures may include delisting from the list of passers. It held that Dizon's irresponsible spreading of false information which directly compromised the integrity of the 2023 Bar Examinations warrants his delisting from the list of bar passers.
Source: Supreme Court decision, B.M. No. 4734.
This report summarizes a public Supreme Court decision and is not legal advice.