Fernando was also a persistent proponent of the clear and present danger test as the only acceptable limitation on the right to free expression, as expressed in his ponencia in Gonzales v. COMELEC, 137 Phil.
In 1982, controversy arose after reports that in the bar examinations held that year, the test booklets had been rechecked in order to confer a passing grade to the son of one of the Justices who had initially flunked.