Former Philippine president Ferdinand Marcos does not hold record for national bar exam

Copyright AFP 2017-2022. All rights reserved.

A photo of a purported news report has been shared thousands of times in a Facebook post which claims former Philippine president Ferdinand Marcos earned the “highest score ever” of 98.01 per cent in the country’s bar examination. The claim is false; the Philippine Supreme Court said former associate justice Florenz Regalado holds the national record for the highest bar exam score; Marcos topped his class with a score of 92.35 per cent in his bar exam in 1939, according to a genuine newspaper report at the time of his graduation.

This post was published here on Facebook on September 14, 2019.

Below is a screenshot of the misleading post: 

Screenshot of Facebook post

The post's caption states: “Did you know? The man who holds the record, until now, of having the highest score ever in the Bar exam is Ferdinand Marcos. More history @ Philippine Shocking History”.

Ferdinand Marcos was the 10th president of the Philippines. He placed the country under martial law in 1972 and was deposed in 1986.

The post contains a photo which purportedly shows a newspaper's front page with a headline that states: “U.P. TOPS BAR”.

U.P. refers to the University of the Philippines.

Below the banner, the masthead reads: “The Philippine Collegian”.

Below the masthead, the text reads: “Marcos - Bar Topnotcher - 1939”.

Below this text is a photo of a young Marcos in academic dress.

Below the photo, a text lists Marcos’ purported bar examination grades: “100% - Criminal Law; 100% - International Law; 100% - Legal Ethics; 98%  - Civil Law; 97% - Procedural Law; 97% - Commercial Law; 95% - Political Law; 98.01% Average”.

The Philippine Collegian is the official student publication of the University of the Philippines Diliman campus. The paper was founded in 1922.

The claim is false; the Philippine Supreme Court told AFP the highest bar examination grade was earned by Florenz Regalado, a former associate justice of the court.

In an email, the court told AFP: “To date, Ret. Justice Florenz D. Regalado still holds the record of having the highest Bar Rating among the Bar Topnotchers”.

Regalado scored an average of 96.7 per cent when he took the bar exam in 1954.

The Supreme Court did not release Regalado’s and Marcos’ grades to AFP, saying it only provides results to the person who took the test.

But Regalado’s grade is shown on the website of Philippine Senate Electoral Tribunal, a body that decides on election protests and whose members include Supreme Court justices. 

Regalado’s profile here states: “Florenz D. Regalado (born October 13, 1928, Concepcion, Iloilo, Philippines) was the 14th Associate Justice of the Supreme Court of the Philippines from July 29, 1988 to October 13, 1998. He graduated magna cum laude in 1954 from the San Beda College of Law, and received his Master of Laws degree from the University of Michigan in 1963.

“He remains the record holder for the highest average in the Philippine Bar Examinations, with his 1954 mark of 96.7%.

“He was a member of the Philippine Constitutional Commission of 1986 which drafted the present Constitution of the Philippines. Before becoming Associate Justice, he served as the Dean of San Beda College of Law.”

Joel Ariate, a researcher at the University of the Philippines who has written about Marcos’ fake war medals among others, told AFP that a framed news report of Marcos topping the bar exam for his class in 1939 could be seen at the family-run Marcos museum in Batac.

Batac is a city in the province of Ilocos Norte some 470 kilometers north of the capital Manila. 

Ariate provided AFP with photos taken from Batac of a framed Philippine Collegian report, dated December 5, 1939.

Below is the photo from Ariate:

Ariate photo

The photo Ariate showed AFP bears the same banner headline as the photo in the Facebook post, but with different elements below the masthead.

Below is a comparison of the Facebook photo (L) and the photo from Ariate (R):

Comparison of Facebook photo (L) and Ariate photo (R)

Several visitors to the Marcos museum in Batac have uploaded their own photos of the framed report by The Philippine Collegian including here, here and here.

A close up photo of the framed report was uploaded here on TripAdvisor.

According to the photos of the original news report, Marcos’ bar exam average was 92.35 per cent.

The report's headline states: "Marcos and Fernandez Lead New Lawyers."

The relevant portion of the framed article states: "Again the College of Law of the State University topped the Bar examinations held last August, Ferdinand Marcos, U.P. obtained the first place with 92.35%, trailed by Ramon C. Fernandez also of U.P. and class valedictorian, in a close second with 90.25%."

Below is a screenshot, with the average circled by AFP:

Screenshot of article