No, the externship program must be facilitated by CLEP and a law clinic.

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Please refer to Sec. 2 of the Rule –

Externship is part of the clinical legal educational program if: (a) it allows students to engage in legal work for the marginalized sectors or for the promotion of social justice and public interest, and (b) it is undertaken with any of the following: (i) the courts, the Integrated Bar of the Philippines (IBP), government offices; and (ii) law school-recognized non-governmental organizations (NGOs).

FAQs #3, in relation to Sec. 2 of the Revised Rule 138-A –

“Private law offices are excluded because the objective of Rule 138-A is to promote social justice and public interest, especially to the marginalized while inculcating in the law students not only the value of ethical lawyering but also public service.”