The Philippines currently has an impressive set of guidelines and regulations concerning pro bono service, including a 60-hour annual service requirement for all licensed attorneys, and a 100-hour service requirement for all new attorneys. Although the government implemented pro bono requirements as a means to address ongoing problems with public access to justice, the state is plagued by the historical understanding that it is an elite institution that only uses the law to disenfranchise, exploit, and disempower citizens. Historically, a number of public interest law non-governmental organizations (‘NGOs’) emerged to address the access to justice issue and to challenge the state. Over time some of these left-leaning NGOs were taken over by younger attorneys born after martial law, who began working with the state. The question in the Philippines is whether this blurring of NGO alternative lawyering and state-led pro bono lawyering will continue and produce a new access to justice identity for lawyers as well as the state. The chapter argues that over time, the lawyers that provided free legal services went from providing such services for the purpose of addressing crimes by the state, to eventually working with the state as a result of pro bono service requirements.