justices through impeachment. The Constitution also transferred the rule-making of the legislature to the Supreme Court on the power to promulgate rules concerning pleading, practice, court procedures, and admission to the practice of law. Japanese occupation Within the brief Japanese occupation of the Philippines, the Court remained with no substantial changes in its organizational structure and jurisdiction. However, some acts and outlines of the Court were required to be approved first by the Military Governor of the Imperial Japanese Force. In 1942, José Abad Santos—the fifth Chief Justice of the Supreme Court—was executed by Japanese troops after refusing to collaborate with the Japanese military government. He was captured on April 11, 1942 in the province of Cebu and was executed on May 7, 1942 in the town of Malabang in Lanao del Sur. Independence and postwar period After the end of the Japanese occupation during World War II, Philippines was granted its independence on July 4, 1946 from the United States. The grant of independence was made through the Treaty of Manila of 1946. In the said treaty, it provides that: In effect of the treaty, the United States Supreme Court ceased to have appellate power to review cases originating from the Philippines after its independence, with exception of those cases pending before the United States Supreme Court filed prior to the country's independence. On June 17, 1948, the Judiciary Act of 1948 was enacted. The law grouped cases together over which the high court could exercise its exclusive jurisdiction to review on appeal, certiorari, or writ of error. In 1973, the 1935 Constitution was revised and was replaced by the 1973 Constitution. Under the said Constitution, the membership of the court was increased to its current number, which is fifteen. All members are said to be appointed by the President alone, without consent, approval, or recommendation of a body or officials. The 1973 Constitution also vested in the Supreme Court administrative supervision over all lower courts which heretofore was under the Department of Justice. The martial law period brought in many legal issues of transcendental importance and consequence: some of which were the legality of the ratification of the 1973 Constitution, the assumption of the totality of government authority by President Marcos, the power to review the factual basis for a declaration of Martial Law by the Chief Executive. Post–EDSA revolution and present After the overthrow of President Ferdinand