G.R. No. L-6784 - Miranda vs. Deportation Board

Petitioners – Natividad Miranda, Luis Miranda, Pedro Miranda, Ramon Miranda, and Faustino Miranda – were charged before the Deportation Board.
They were accused of entering the Philippines by means of fraud and misrepresentation; although being children of Chinese parents, they allegedly misrepresented themselves as the legitimate children of a Filipino citizen.
Arrest and temporary detention occurred at the detention station of the Bureau of Immigration; later they were released upon posting bonds.
On June 18, 1953, petitioners filed a motion to quash the deportation charges on the ground that they were Filipino citizens, questioning the Board’s jurisdiction.
At the hearing scheduled for July 7, 1953, petitioners filed a petition for a writ of habeas corpus seeking suspension of the deportation proceedings and their release.
The controversy centered on the scope of the Deportation Board’s jurisdiction and whether a mere plea of citizenship was sufficient to bar its proceedings.
The Court noted that although the Board’s power exists solely for alien and undesirable persons, it retains the authority to adjudicate evidence regarding citizenship.

From 1946 to 1953, passing marks for the bar examination varied due to differing grading practices and circumstances.
Initially, candidates were admitted on a minimum general average of 75%; in earlier years (1946–1949) resolution practice sometimes allowed lower averages (72%–74%) in view of post-war hardships.
Numerous unsuccessful candidates, disputing the inconsistency and alleged discrimination in the grading system, sought admission to the Bar.

Congress, by way of a corrective measure, enacted RA 972 to fix the passing marks on a sliding scale for examinations held from July 4, 1946 through 1955.
The law provided that candidates who obtained a lowered general average – 70% for examinations up to August 1951, 71% in 1952, 72% in 1953, 73% in 1954, and 74% in 1955 – without any subject falling below 50% would be admitted upon taking the oath.
It also directed that a candidate who achieved a grade of 75% in any subject would be deemed to have passed that subject and that grade would be carried forward to subsequent examinations.

Petitioners argued that the statutory lowering of the passing grade was justified given the post-war handicaps such as inadequate reading materials and insufficient preparation.
Opponents contended that the law interfered with the traditional judicial function of determining the qualifications for admission.
The controversy raised issues of retroactivity, a valid legislative classification versus class legislation, and the separation of powers between the legislative and judicial branches.
A series of petitions for admission based on RA 972 arose, with attached annexes documenting the statistical performance of bar candidates for 1946–1953, and detailed motions for reconsideration by individual candidates.

The Supreme Court was asked to comment on the constitutionality of RA 972, especially in view of its retroactive effect on previously resolved bar examination results.
Public hearings were held, with inputs from law deans, professors, bar representatives, and practicing attorneys.
The majority opinion and dissenting opinions expressed divergent views on whether fixing different passing marks for different examination years amounted to an impermissible encroachment on the judicial prerogative.
The Court issued a resolution declaring:

The portions of the law affecting examinations from 1946 to 1952 and the entire Article 2 as unconstitutional and void.
The part of Article 1 referring to examinations from 1953 to 1955 was upheld, thereby permitting candidates of those years who obtained the lower general average, as specified, to be admitted upon taking the oath.

The decision was accompanied by concurring and dissenting opinions regarding the proper division of power between the Legislature and the Judiciary in matters of legal qualification.

Whether the mere plea of Filipino citizenship by the petitioners removes the jurisdiction of the Deportation Board to conduct the deportation proceedings.
Whether the Board’s incidental power to require evidence (e.g., blood tests) is proper in determining the true citizenship status of the petitioners.
The appropriate balance between administrative authority and judicial review in matters of deportation where allegations of fraud are raised.

Whether Congress, in enacting RA 972, exceeded its constitutional authority by effectively altering the passing mark for practical admission to the Bar retroactively.
Whether the classification under RA 972 – which provided a sliding scale of passing averages for different examination years – was valid or amounted to arbitrary and discriminatory class legislation.
Whether the law improperly interfered with the judicial function of determining the qualifications for admission to practice law, an authority historically vested in the Supreme Court.
Whether the retroactive application of the law, thereby altering previously final resolutions denying candidates admission, violates principles of due process, vested rights, or the separation of powers.
Whether the legislative power to amend or supplement the rules on admission (as granted to Congress) extends to the adjudication of individual qualifications and past judicial determinations.