Philippine Bar Examination - Grading System - Bar Topnotchers - Highest and Lowest Topnotcher Grades

Highest and Lowest Topnotcher Grades

In the Philippine Bar's recorded history, the highest grade first recorded was the 92% garnered in 1913 by Manuel A. Roxas of the UP College of Law. The following year, 1914, Atty. Roxas' feat was bested by the 93% obtained by first placer Manuel C. Goyena (also from the UP College of Law). Atty. Goyena's top mark was tied by 1916-first placer Paulino Gullas (future Congressman from Cebu), another alumnus of the UP College of Law.

Another 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 bacholer's degree in law, earning it in 1946. The only other instance of a tie at first place of 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 while Atty. Hilbay is a Professor of Law at the UP College of Law.

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.

But the diamond standard (the highest general average ever obtained among all bar topnotchers in recorded history) was set in 1954 when Florenz D. Regalado (future Supreme Court Associate Justice) of the San Beda College of Law scored 96.7% when he topped the 1954 Philippine Bar Examinations. To date, Atty. Regalado's feat remains unsurpassed and may never be equalled (much less topped).

The lowest grade was obtained by Ateneo Law School's Mercedita L. Ona, 83.55%, 2008, 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. Atty. Ona was the just the latest of women 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.

Below is a listing of all 100 first-placers (from 1913 to 2012) ranked from highest to lowest in terms of rating obtained. It should be noted however that bar ratings are not exactly comparable from year-to-year as the difficulty of the exams varies through the years.

A famous (almost anecdotal) incident in the history of the Philippine bar examinations supposedly happened in 1939 when Ferdinand Marcos topped the examinations with almost perfect score of 98.5%. However, after some deliberation on his grade (and after undergoing an oral examination before the supreme court, the result of which is impressive), the supreme court justices decide to prune down his grade to 92.35% to mitigate the effect of insinuations that he cheated on the said examinations.