His latest film was smuggled out of Iran by means that have not been specified by festival director Dieter Kosslick.
"I think it is important that we had these films, these political films, because they actually reflect what happens there," Kosslick said.
Scott Roxborough, film critic for the Hollywood Reporter, said the choice of Panahi's film "wasn't a surprise."
"I had it up top before the festival even started just because of Panahi's record," he said, "and also, of course, the political aspect of the film, the fact that he shot it in secret, the fact that he's been banned from filmmaking by the Iranian government and Berlin always likes to celebrate political films if they have a chance."
Two other films with political messages also received top prizes.
The Chilean film "The Club" directed by Pablo Larrain, about defrocked Roman Catholic priests, won the Silver Bear Grand Jury Prize.
"This is an important artistic and political acknowledgment of the film that makes me very proud," Larrain said, adding that the award should assure the film a wider audience.
"Ixcanul" (Volcano), a Guatemalan film directed by Jayro Bustamente about the hard life of Mayan coffee growers, won the Silver Bear Alfred Bauer Prize.
Although the film focuses mostly on indigenous women whose lives are complicated by an unwanted pregnancy, Bustamente said "we avoided being folkloristic."
"I hope we were able to help the people in Guatemala realise what culture they have there," he said.
The award for best director was shared by Radu Jude of Romania for "Aferim!" and Polish director Malgorzata Szumowksa for "Body."
Tom Courtenay received the award for best actor for his performance in Andrew Haigh's "45 Years" and Charlotte Rampling received the best actress award for the same film.
The award for best script went to Chilean director Patricio Guzman for "El Boton de Nacar" (The Pearl Button).
The awards were decided by a seven-person jury headed by Aronofsky. The 65th edition of the 11-day festival saw more than 400 films screened, 19 of them competing for the main prize.
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