AI-generated
Updated 3rd February 2025
In re: Cunanan, et al.
The Supreme Court declared Republic Act No. 972 (the "Bar Flunkers’ Act of 1953") unconstitutional for infringing on the Court’s exclusive authority to regulate bar admissions. The law retroactively lowered passing grades for bar exams from 1946–1952, allowing 1,094 unsuccessful candidates admission. The Court ruled it violated separation of powers and constituted arbitrary class legislation.

Primary Holding

The Supreme Court declared Republic Act No. 972 unconstitutional, except for the portion relating to bar examinations from 1953 to 1955, which remained valid due to a lack of unanimity in the decision.

Background

Post-WWII bar candidates who narrowly failed petitions sought admission under RA 972, which retroactively reduced passing averages. The Court initially adjusted passing grades annually but rejected legislative interference, citing the need to protect public interest in legal practice standards.

History

  • 1946-1953: Unsuccessful bar candidates failed to meet the required passing average.

  • 1951: Senate Bill No. 12, reducing the passing average, was vetoed.

  • 1953: Republic Act No. 972 was passed without the President's signature.

  • March 18, 1954: The Supreme Court issued its resolution.

Facts

  • 1. RA 972 lowered passing averages for bar exams (70% for 1946–1951, scaling to 74% by 1955). Petitioners argued wartime/post-war hardships justified relief. The Court had previously admitted candidates with adjusted averages but refused to extend this via legislative mandate.

Arguments of the Petitioners

  • 1. Post-war conditions (lack of materials, inadequate preparation) justified leniency; Congress had authority under the Constitution to modify bar rules; previous Court adjustments created inequity.

Arguments of the Respondents

  • 1. RA 972 violated judicial independence, was arbitrary class legislation, and risked lowering bar standards. The Solicitor General emphasized the Court’s constitutional duty to uphold professional competence.

Issues

  • 1. Whether RA 972 encroached on the judiciary’s exclusive power to admit attorneys
  • 2. Whether it violated due process and equal protection by creating arbitrary classifications
  • 3. Whether its title covered Section 2’s provisions

Ruling

  • 1. The Court unanimously invalidated RA 972 for usurping judicial authority, creating irrational classifications, and violating the constitutional requirement that a law’s title reflect its content. Only the 1953–1955 provisions survived as prospective legislative adjustments.

Doctrines

  • 1. Judicial supremacy over bar admissions (State v. Cannon).
  • 2. Unconstitutional class legislation if no rational basis (In re Day).
  • 3. Separation of powers bars legislative interference in judicial functions (Guariña Case).

Key Excerpts

  • 1. “Legislative power... cannot be exercised in the manner here attempted” (State v. Cannon).
  • 2. “The public interest demands adequate preparation... confidingly entrusted to those inadequately prepared would be to create a serious social danger.”

Precedents Cited

  • 1. In re Day (invalidated class-based bar legislation).
  • 2. Guariña Case (affirmed judicial discretion in admissions).
  • 3. State v. Cannon (struck down legislative admission mandates).

Statutory and Constitutional Provisions

  • 1. 1935 Constitution, Article VIII, Section 13 (Court’s rule-making power over bar admissions).
  • 2. 1935 Constitution, Article VI (legislative powers and title requirements).