Case Digest (G.R. No. 166097)
Facts:
The case involves Yasuyuki Ota, a Japanese national married to a Filipina, who has resided in the Philippines for over ten years. He graduated from Bicol Christian College of Medicine on April 21, 1991, with a Doctor of Medicine degree. After completing a one-year postgraduate internship at the Jose Reyes Memorial Medical Center, Ota applied to take the medical board examinations to obtain a medical license. The Professional Regulation Commission (PRC) required him to submit an affidavit of undertaking, which included a stipulation that he would not practice medicine until he could prove that reciprocity existed between Japan and the Philippines regarding the admission of foreigners into the medical profession. Ota submitted a notarized English translation of Japan's Medical Practitioners Law, authenticated by the Consul General of the Philippine Embassy in Japan, which allowed him to take the medical board examinations in August 1992, which he passed.
However, on March...
Case Digest (G.R. No. 166097)
Facts:
Background of the Case
- Yasuyuki Ota (respondent) is a Japanese national married to a Filipina and has resided in the Philippines for over 10 years.
- He graduated from Bicol Christian College of Medicine on April 21, 1991, with a Doctor of Medicine degree.
- After completing a one-year postgraduate internship at Jose Reyes Memorial Medical Center, he applied to take the medical board examinations to obtain a medical license.
Requirements Imposed by PRC
- The Professional Regulation Commission (PRC) required Ota to submit an affidavit of undertaking, stating that if he passed the exams, he would not practice medicine until he proved the existence of reciprocity between Japan and the Philippines in admitting foreigners to practice medicine.
- Ota submitted a duly notarized English translation of Japan’s Medical Practitioners Law, authenticated by the Philippine Embassy’s Consul General in Japan, Jesus I. Yabes.
- He was allowed to take the August 1992 Medical Board Examinations, which he passed.
Denial of License
- On March 8, 1993, the Board of Medicine (Board) denied Ota’s request for a medical license, claiming no genuine reciprocity existed between Japan and the Philippines, as no Filipino or foreigner could practice medicine in Japan.
Legal Action by Ota
- Ota filed a Petition for Certiorari and Mandamus before the Regional Trial Court (RTC) of Manila on June 24, 1993, alleging that the Board and PRC acted arbitrarily in refusing to issue his license, violating Section 20 of Republic Act (R.A.) No. 2382 (The Medical Act of 1959).
RTC Decision
- On October 19, 2003, the RTC ruled in favor of Ota, finding that he had adequately proven reciprocity between Japan and the Philippines. The court ordered the Board to issue Ota’s Certificate of Registration and license to practice medicine.
Appeal to the Court of Appeals (CA)
- The Board and PRC appealed, arguing that while Ota showed foreigners could practice medicine in Japan, he failed to prove that the conditions were practical and attainable for Filipinos. They also claimed that the power to issue licenses is discretionary and not compellable by mandamus.
- The CA affirmed the RTC’s decision, prompting the Board and PRC to file a Petition for Review before the Supreme Court.
Issue:
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Ruling:
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Ratio:
Reciprocity Under the Law:
- Section 9 of R.A. No. 2382 and Section (j) of P.D. No. 223 require a foreign applicant to submit competent and conclusive evidence, confirmed by the Department of Foreign Affairs (DFA), showing that their country’s laws permit Filipinos to practice medicine under the same rules and regulations.
- Ota submitted the Medical Practitioners Law of Japan, authenticated by the Philippine Embassy, which allows foreigners to practice medicine in Japan under certain conditions.
Ministerial Duty of the PRC and Board:
- The Court emphasized that the issuance of a license is a ministerial duty once the applicant has complied with all legal requirements. The use of the word “shall” in Section 20 of R.A. No. 2382 indicates a mandatory obligation, not a discretionary power.
No Need to Prove Practical Attainability:
- The Court rejected the petitioners’ argument that Ota needed to prove that the conditions for practicing medicine in Japan are practical and attainable for Filipinos. The law only requires proof that the foreign country’s laws permit Filipinos to practice medicine under the same rules.
Distinction from Professional Regulation Commission v. De Guzman:
- The Court distinguished this case from De Guzman, where doubts about the integrity of examination results justified the PRC’s discretion. In Ota’s case, there was no doubt about his qualifications or compliance with the law.
Public Policy and Protection of Rights:
- The Court stressed that while the state has the power to regulate professions, such power must not be exercised arbitrarily. Ota had a legitimate right to practice medicine after fulfilling all legal requirements.
Conclusion:
The Supreme Court upheld the decisions of the RTC and CA, ruling that Ota had established reciprocity between Japan and the Philippines and that the PRC and Board had a ministerial duty to issue his medical license. The petition was denied for lack of merit.