Case Digest (G.R. No. 225920) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On March 18, 1954, the Supreme Court of the Philippines issued a Resolution in In the Matter of the Petitions for Admission to the Bar of Unsuccessful Candidates of 1946 to 1953; Albino Cunanan et al., Petitioners, addressing challenges to Republic Act No. 972, the so-called “Bar Flunkers’ Act of 1953.” Enacted June 21, 1953 without the President’s signature, RA 972 retroactively reduced the required general average for bar examinees from 75% to 70% for 1946–1951, then incrementally raised it to 74% for 1955, while maintaining a 50% minimum per subject and purporting to validate past resolutions of this Court. Of 12,230 examinees, 1,094 fell within the lowered margins; 604 filed petitions invoking RA 972 or seeking reconsideration of their grades. After denying all motions to revise grades on their merits, the Court confined its inquiry to the constitutionality of RA 972 under the 1935 Constitution, invited amici curiae briefs, and, following full deliberation by eight participa Case Digest (G.R. No. 225920) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Bar Examination Standards and Judicial Practice
- Under Rule 127, section 14, Rules of Court, a candidate must obtain a general average of 75% in all subjects, without falling below 50% in any subject, to pass the Bar.
- Since 1946 the Supreme Court, noting varying difficulty and grading strictness, admitted below-75% averages by way of resolution:
- 1946: 72% (August and November)
- 1947: 69%
- 1948: 70%
- 1949: 74%
- 1950–1953: restored to 75%, but 74% was deemed equivalent by resolution
- Legislative History of Republic Act No. 972
- Senate Bill No. 12 (1951) sought to reduce the passing average to 70% retroactive to 1946; the President vetoed it after an adverse Supreme Court comment.
- Senate Bill No. 371 (1953) revised the standard:
- 70% for 1946–1951 exams; 71% for 1952; 72% for 1953; 73% for 1954; 74% for 1955 examinations; no grade below 50%; partial credit for 75% in any subject.
- Became Republic Act No. 972 on June 21, 1953, by presidential inaction during an election year.
- Post-Enactment Petitions and Court Review
- From 1946–1953, 12,230 took the exams; 5,421 passed under existing rules; 1,168 failed within the percentage bands later covered by RA 972.
- Of these 1,168, 1,094 stood to benefit under RA 972; 604 filed petitions for admission or grade reconsideration.
- The Supreme Court first reviewed pending motions for paper revision—none succeeded—and then set a hearing solely on the constitutionality of RA 972.
Issues:
- Whether RA 972’s retroactive reduction of passing averages invades the Supreme Court’s exclusive judicial power to admit to the Bar.
- Whether Congress, under Const. Art. VIII, § 13, may repeal, alter, or supplement Rules of Court to compel admission of determinate individuals.
- Whether RA 972 constitutes arbitrary or unreasonable class legislation in violating equal protection.
- Whether Article 2 of RA 972 is void for lacking inclusion in the Act’s title, contrary to Const. Art. VI, § 21.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)