Manila: The Supreme Court (SC) has found a Bar review coach guilty of indirect contempt for spreading false information on Facebook about the 2023 Bar examinations, specifically claiming that artificial intelligence (AI) would be used for checking the results. In a per curiam decision, the SC en banc held Edgar Dizon, administrator of the Facebook group Bar Law for Dummies, responsible for the misleading post.
According to Philippines News Agency, the court fined Dizon PHP30,000 and ordered the removal of his name from the list of 2016 Bar passers. The controversy began on September 21, 2023, when a post from Dizon's Facebook group, under the account "Tsidkenu Dizon," alleged that AI would handle the sorting, checking, and correction of the 2023 Bar Examinations. The post also advised candidates to start answers with "YES" or "NO," claiming this was a requirement for the AI's sorting mechanism.
The Office of the 2023 Bar Chair (BCO), led by Associate Justice Ramon Paul Hernando, promptly investigated the source and impact of the post. The BCO issued an advisory to clarify that human examiners, all experts in their respective fields, would handle the examination checks. Despite this clarification, Dizon threatened legal action against the SC and demanded a public apology within 24 hours, refusing to remove the post.
Dizon also sent multiple emails to the SC's Judiciary Public Assistance Section, claiming that the advisory had a chilling effect on him. He denied spreading misinformation and requested a statement from the court to correct the advisory. However, when directed by the SC to explain his actions, Dizon admitted owning the Facebook account but argued that his post suggested AI would "help" rather than replace human examiners.
The SC found Dizon's explanations unconvincing, citing him under Rule 71, Section 3 of the Rules of Court for indirect contempt. The court concluded that Dizon's actions interfered with the conduct of the 2023 Bar Examinations and undermined the integrity of the exams and the SC's supervisory role over the legal profession. The misinformation caused confusion, forcing Bar officials to allocate time and resources to address the issue.
The SC also criticized Dizon for his lack of remorse, as he refused to acknowledge the harm caused and continued to demand an apology from the court. Additionally, the court warned him against unauthorized legal practice, as he conducted Bar review coaching sessions and authored Bar review materials despite not having taken the lawyer's oath due to pending criminal cases.
In a separate concurring opinion, Senior Associate Justice Marvic Leonen agreed with the decision to punish Dizon, emphasizing the need to balance the court's contempt powers with the constitutional right to free speech, including legitimate court criticism.
