G.R. No. 88259 - Board of Medical Education vs. Alfonso

The Board of Medical Education and Lourdes R. Quisumbing, in her capacity as Secretary of the Department of Education, Culture and Sports and Chairperson of the Board of Medical Education, were Petitioners seeking a writ of certiorari.
Hon. Daniel P. Alfonso, Presiding Judge of the Regional Trial Court, Branch 74, Antipolo, Rizal, and the Philippine Muslim-Christian College of Medicine Foundation, Inc. (hereafter the College) were Respondents in the case below.

The College was founded in 1981 to produce physicians addressing Muslim health needs and initially proposed to be located in Zamboanga City.
Because of the unstable peace and order situation in Mindanao, the College commenced operations in Antipolo, Rizal, obtained a temporary permit there, later adopted Antipolo as its permanent site, and changed its name to Rizal College of Medicine.

In 1985 the DECS and the Board of Medical Education authorized the Commission on Medical Education to study all medical schools, and the Commission's report showed the College fell very short of minimum standards.
A team of inspectors (including Doctors Florentino Herrera, Jr., Elena Ines Cuyegkeng, Horacio Estrada, Jose V. Silao, Jr., and Andres L. Reyes) recommended closure based on findings that included improper location and absence of Muslim-related curriculum; lack of university affiliation; absence of a base hospital for clinical training; and that more than sixty percent of faculty were not full-time, resulting in shortened and irregular classes and poor teaching.
The College disputed the findings as biased and requested re-evaluation; in May 1987 the Board of Medical Education sent a second team which confirmed the earlier findings and recommended phase-out of the school.
A third team verified the first two reports on June 23, 1987.
A fourth evaluation on March 4–5, 1988 by a Board team adjudged the College "inadequate" in college, curriculum, facilities, teaching hospital, and studentry, and recommended denial of government recognition.
The Board recommended to the DECS the closure of the College effective at the end of the 1988–1989 school year.

At the College's request another team inspected on June 18, 1988 and again found serious deficiencies in clinical facilities and library operations, inadequate faculty with no prospects for growth, substandard student profile, and an almost total lack of academic medicine development; the team recommended closure and dispersal provisions for students.
On June 23, 1988 Secretary Quisumbing informed Mr. Victor Sumulong, Chairman of the College's Board of Trustees, of the Board's decision to close the College.
Mr. Sumulong proposed a gradual phase-out beginning 1989–1990 to minimize dislocation and financial loss; the Board allowed continued operation only until May 1989, declared its decision final and unappealable, and promised assistance in student relocation and institutional rehabilitation.

The College appealed the closure decision to the Office of the President alleging *grave abuse of discretion* by the Secretary.
Executive Secretary Catalina Macaraig, Jr. on February 16, 1989 found "no reason to disturb" the contested decision and affirmed it.

On March 2, 1989 the College filed Civil Case No. 1385 in the Regional Trial Court, Branch 74, Antipolo, Rizal, naming Secretary Quisu...(Subscriber-Only)

Whether the respondent judge committed grave abuse of discretion in issuing the writ of preliminary injunction dated May 10, 1989 restraining enforcement of Secretary Quisumbing's closure order.
Whether the Secretarial and Board decisions closing the College were within the scope of their lawful powers and not arbitrary, oppressive, or violative of due process.
Whether the College was entitled to injunctive relief restraining the administrative closure.

Whether courts have the authority to review and substitute their judgment for administrative determinations that an educational institution...(Subscriber-Only)