Professional Regulation Commission v. De Guzman
REITERATIONFacts
The Antecedents: Respondents, graduates of Fatima College of Medicine, passed the February 1993 Physician Licensure Examination. The Board of Medicine noted unusually high and clustered scores among Fatima examinees in Biochemistry and Obstetrics & Gynecology, prompting an investigation. The National Bureau of Investigation (NBI) concluded that the Fatima examinees likely had prior access to the test questions. Consequently, the Board issued Resolution No. 19, withholding the registration of these examinees, and later Resolution No. 26, charging them with immorality, dishonest conduct, fraud, and deceit, recommending the nullification of their test results. Procedural History: Respondents filed a special civil action for mandamus with the Regional Trial Court (RTC) of Manila, seeking to be allowed to take their physician's oath and be registered. The RTC granted a preliminary mandatory injunction, which the Professional Regulation Commission (PRC) challenged via certiorari to the Court of Appeals (CA). The CA nullified the injunction, a decision affirmed by the Supreme Court. Subsequent proceedings in the RTC were marked by procedural disputes, including the PRC's counsel's repeated absences, leading to the CA nullifying certain RTC orders and remanding the case for proper cross-examination and presentation of evidence. The RTC eventually rendered a decision allowing the respondents to take their oath and register, which the PRC appealed to the CA. The CA affirmed the RTC's decision, leading to the present petition. The Petition: This petition for review under Rule 45 of the 1997 Rules of Civil Procedure seeks to nullify the Court of Appeals' decision affirming the RTC's judgment that allowed respondents to take their physician's oath and register. Petitioners argue that a writ of mandamus will not lie because the respondents do not have a clear legal right to the act demanded, as their moral fitness to practice medicine is in doubt due to the irregularities in the examination, and the PRC has discretion in issuing licenses. They contend that the CA overlooked its prior pronouncements and the Supreme Court's resolution in G.R. No. 112315, which affirmed that the issuance of a license is discretionary if there are doubts about the examinee's fitness. The core issue is whether the CA erred in sustaining the trial court's judgment that respondents are entitled to a writ of mandamus, considering the pending administrative case and the alleged lack of a clear legal duty on the part of the petitioners.
Issue(s)
Whether respondents have a valid cause of action for mandamus against petitioners in light of this Court's resolution in G.R. No. 112315 affirming the Court of Appeals' decision that the issuance of a license is not automatic if there is doubt as to the moral fitness of examinees; specifically, regarding the existence of a duty to issue certificates of registration and the right of respondents to be registered as physicians. Whether the petition for mandamus could proceed despite the pendency of Administrative Case No. 1687, which was lodged to determine the moral fitness of respondents to become doctors; specifically, regarding the ripeness of the petition for mandamus.
Ruling
The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the assailed decision of the Court of Appeals and the resolution denying reconsideration, and NULLIFIED and SET ASIDE the writ of mandamus issued in Civil Case No. 93-66530. The decision is binding only on the remaining respondents and the petitioners.
Ratio Decidendi
On the existence of a duty to issue certificates of registration and the right of respondents to be registered as physicians: The Court held that while Section 20 of Rep. Act No. 2382 uses the word "shall" regarding the issuance of certificates of registration, implying a ministerial obligation, this must be read in conjunction with other provisions of the Act. The Board of Medicine has the power under Section 22 to disapprove applications or withhold registration if an examinee has not "satisfactorily passed" the examinations. The unusually high and clustered scores, coupled with the Board's findings of "immorality, dishonesty, fraud, and deceit" in Administrative Case No. 1687, raised grave doubts about the satisfactory compliance of the respondents. The Board's subsequent decision cancelling examination papers and debarring respondents for one year indicated that their compliance was not satisfactory, thus negating the ministerial duty to register them until their moral and mental fitness could be ascertained. The Court reiterated that mandamus is not to establish a right but to enforce one that is already established. A license to practice medicine is a privilege, not a right, and its grant is subject to regulation by the State under its police power to protect public health and safety. While citizens have the right to select a profession, this right is not absolute and can be regulated by fair, reasonable, and equitable admission and academic requirements. The Medical Act of 1959 provides the conditions for licensure, and an applicant must possess all qualifications and none of the disqualifications. If doubt taints the compliance as less than satisfactory, the privilege will not issue, and mandamus cannot be used to secure it without thwarting legislative will. On the ripeness of the petition for mandamus: The Court affirmed that mandamus will not lie when administrative remedies are still available. However, the doctrine of exhaustion of administrative remedies does not apply when a pure question of law is raised. In this case, the issue of whether the Court of Appeals erred in not ordering the dismissal of the mandamus case had been rendered moot by the subsequent filing of an appeal by the petitioners to the Court of Appeals after the RTC rendered its decision. The Court found no reversible error in the appellate court's refusal to dismiss the case on the ground of prematurity, as a pure question of law was involved.
Main Doctrine
A writ of mandamus will not lie to compel the administration of the physician's oath and registration if there are doubts regarding the satisfactory compliance with the requirements for licensure, especially when administrative investigations into moral and mental fitness are pending or have resulted in adverse findings, as the issuance of a license is not an automatic right but a privilege that requires satisfactory fulfillment of all legal conditions.