Lupangco v. Court of Appeals
REITERATIONFacts
The Antecedents: The Professional Regulation Commission (PRC) issued Resolution No. 105, part of its "Additional Instructions to Examiness," prohibiting examinees from attending review classes, receiving handouts, or tips from any review institution or personnel during the three days immediately preceding and on the examination day. Violation would subject the examinee to sanctions prescribed by the PRC's Rules and Regulations. Procedural History: Petitioners, reviewees for the accountancy licensure examinations, filed a complaint with the Regional Trial Court (RTC) of Manila, Branch 32, seeking an injunction against the enforcement of Resolution No. 105 and a declaration of its unconstitutionality. The PRC filed a motion to dismiss, arguing the RTC lacked jurisdiction. The RTC denied the motion, asserted jurisdiction, and enjoined the PRC from enforcing the resolution. The PRC then filed a petition with the Court of Appeals (CA) to nullify the RTC's order. The CA granted the PRC's petition, declared the RTC's order void for want of jurisdiction, and directed the dismissal of the case, holding that the PRC and RTC are co-equal bodies and thus cannot interfere with each other's acts. The Petition: Petitioners seek a review of the CA's decision, questioning whether the RTC has the authority to pass upon the validity of the PRC's administrative acts and whether the PRC can lawfully prohibit examinees from attending review classes or receiving materials three days before an examination.
Issue(s)
Whether the Regional Trial Court has jurisdiction to review and enjoin the enforcement of administrative acts of the Professional Regulation Commission. Whether Resolution No. 105 of the Professional Regulation Commission, prohibiting examinees from attending review classes or receiving materials three days before an examination, is constitutional.
Ruling
The Supreme Court reversed and set aside the decision of the Court of Appeals, declared Resolution No. 105 null and void, and held that the Regional Trial Court has jurisdiction to entertain the case and enjoin the respondent PRC from enforcing its resolution. The decision is immediately executory.
Ratio Decidendi
On the jurisdiction of the Regional Trial Court: The Court held that the Regional Trial Court (RTC) has jurisdiction to review and enjoin the enforcement of administrative resolutions of the Professional Regulation Commission (PRC). The Court distinguished the PRC from the Securities and Exchange Commission (SEC), noting that specific laws provide a direct appeal route from the SEC to the Supreme Court, a procedure absent for PRC resolutions. The Court emphasized that Presidential Decree No. 223, which created the PRC, does not provide for an appeal to the Court of Appeals or the Supreme Court. Therefore, challenges to PRC resolutions, especially those alleged to be unconstitutional, fall within the general jurisdiction of the RTC, as even acts of the Office of the President are subject to judicial review by the RTC. The cited cases of National Electrification Administration vs. Mendoza, Pineda vs. Lantin, and Philippine Pacific Fishing, Inc. vs. Luna were deemed not in point because they specifically dealt with the SEC, for which a different statutory appeal process exists. The Court reiterated that RTCs have original jurisdiction over all civil actions where the subject of litigation is not capable of pecuniary estimation, which includes enjoining the enforcement of administrative actions. On the constitutionality of Resolution No. 105: The Court declared Resolution No. 105 unconstitutional, unreasonable, and arbitrary. While acknowledging the PRC's commendable purpose of preserving the integrity of licensure examinations, the Court found the prohibition too broad and unreasonable, preventing examinees from attending review classes or receiving materials, which are lawful means of preparation. The Court noted that the PRC has no authority to dictate how examinees should prepare for examinations and that such restrictions infringe upon the examinees' right to liberty, which includes the freedom to pursue callings and vocations and to acquire useful knowledge for their happiness and personal growth. Furthermore, the resolution was found to violate the academic freedom of schools and review centers, which have the autonomy to determine the best methods for their students' preparation. The Court suggested that the PRC should focus on identifying and eradicating the sources of examination leakages, such as corrupt officials or fixers, rather than curtailing the legitimate rights and freedoms of examinees.
Main Doctrine
Regional Trial Courts have jurisdiction to review and enjoin the enforcement of administrative resolutions of the Professional Regulation Commission, as the latter is not a co-equal body with the RTC, and its resolutions, when purely administrative, are not subject to the exclusive appellate jurisdiction of the Court of Appeals.