Professional Regulation Commission v. Alo
REITERATIONFacts
The Antecedents: Respondent Dayamon Didato Alo (Alo) was charged with unprofessional conduct and/or dishonorable conduct before the Board for Professional Teachers (Board) for allegedly using a falsified Board Resolution No. 671 dated September 28, 2000, in obtaining her certificate of registration and professional license as a teacher on September 14, 2007. Alo claimed she was a holder of a Bachelor of Science in Elementary Education degree and had been a public elementary school teacher from 1995 to 2006. She applied for a license under Section 26(C) of Republic Act No. (RA) 7836, which allows registration without examination under certain conditions. Alo denied using any falsified resolution and argued that the PRC personnel could have easily verified its authenticity. She also invoked Section 5 of RA 4670 (Magna Carta for Public School Teachers) regarding security of tenure. Procedural History: The Board found Alo guilty and revoked her certificate of registration and license. Alo's motion for reconsideration was denied. Without elevating the case to the Professional Regulation Commission (PRC), Alo directly filed a petition for review with the Court of Appeals (CA). The CA granted Alo's petition, reversing the Board's decision, citing insufficient evidence and failure to present the alleged falsified document and the authentic copy of Board Resolution No. 671. The CA also found that Alo's right to due process was violated as the Board's decision was based on grounds not included in the formal charge. The PRC and the Board's motion for reconsideration, which attached a copy of the original Board Resolution No. 671, was denied by the CA. The Petition: The PRC filed a petition for review on certiorari with the Supreme Court, raising two issues: (1) whether the CA has jurisdiction to directly review the Board's decision, and (2) whether the Board correctly found Alo guilty of falsification.
Issue(s)
Whether the Court of Appeals has jurisdiction to directly review the Board's decision, considering that the same belongs to the PRC, and whether Alo exhausted administrative remedies. Whether the Board correctly found respondent guilty of falsification and accordingly revoked her certificate of registration and professional license.
Ruling
The petition is granted. The Court of Appeals' Decision and Resolution are reversed and set aside. The September 11, 2012 Decision of the Board for Professional Teachers is reinstated.
Ratio Decidendi
On the jurisdiction of the Court of Appeals and exhaustion of administrative remedies: The Supreme Court held that the Court of Appeals has jurisdiction to directly review decisions of the Board for Professional Teachers under Rule 43 of the Rules of Court. The Court clarified that while Section 9(c) of RA 8981 and PRC Resolution No. 2013-775 outline the PRC's appellate jurisdiction over Board decisions, these provisions do not divest the CA of its own appellate jurisdiction conferred by Section 9(3) of BP 129, as amended by RA 7902, and Rule 43 of the Rules of Court. The Board exercises quasi-judicial functions when it hears and investigates cases arising from violations of laws and promulgates decisions affecting private parties, making its decisions subject to a Rule 43 petition before the CA. The list of quasi-judicial agencies in Rule 43 is not exclusive, and the Board falls within this category. Despite affirming the CA's jurisdiction, the Supreme Court ruled that Alo failed to exhaust administrative remedies. Alo directly filed a petition for review with the CA without first appealing to the PRC, which was the proper procedural step and was still within the 15-day reglementary period. The Court emphasized that the doctrine of exhaustion of administrative remedies is grounded on practical reasons, allowing agencies to correct their own errors and sparing litigants from costly court processes. None of the recognized exceptions to this doctrine were present in Alo's case, thus the CA should have dismissed the petition for lack of cause of action. On the merits of the falsification charge: The Supreme Court found that Alo was not qualified to obtain a professional teacher's license and certificate of registration under Section 26(C) of RA 7836. Alo graduated in April 1995 and commenced teaching in the same year, making her ineligible as an applicant under Section 26(C) because the basis of incumbency was reckoned as of December 16, 1994. Furthermore, even if she were qualified, she failed to register by the extended deadline of September 19, 2000, as provided by BPT Resolution 600-1997, thus forfeiting her privilege to practice the teaching profession without examination. The Court also found substantial evidence of misrepresentation, noting that Alo wrote the notation "671 s'2000 E/C" on the Registry Book for Teachers, referencing Board Resolution No. 671, despite her claim of never knowing of its existence. This notation indicated she falsely represented herself as qualified under that resolution, constituting unprofessional or dishonorable conduct, regardless of whether she relied on a falsified copy or deliberately misrepresented her qualifications.
Main Doctrine
The Court of Appeals has jurisdiction to directly review decisions of the Board for Professional Teachers under Rule 43 of the Rules of Court, as the Board exercises quasi-judicial functions. However, a party must exhaust administrative remedies by appealing to the Professional Regulation Commission (PRC) before resorting to the CA, unless an exception to the doctrine of exhaustion of administrative remedies applies. Furthermore, the charge of using a falsified Board Resolution is substantiated by evidence of misrepresentation, even if the falsified document itself was not presented, when the respondent's notation on the registry book indicates knowledge of and reliance on such a resolution.