Case Digest (G.R. No. 166097) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the case Board of Medicine, Dr. Raul Flores (now Dr. Jose S. Ramirez), in his capacity as Chairman of the Board, Professional Regulation Commission, through its Chairman, Hermogenes Pobre (now Dr. Alcestis M. Guiang), petitioners, vs. Yasuyuki Ota, respondent (G.R. No. 166097, July 14, 2008), the respondent is a Japanese national who married a Filipina and resided in the Philippines for over ten years. He obtained his Doctor of Medicine degree from Bicol Christian College of Medicine on April 21, 1991, and completed a one-year postgraduate internship at Jose Reyes Memorial Medical Center. Seeking a Philippine medical license, he filed an application with the Professional Regulation Commission (PRC) and submitted an affidavit of undertaking not to practice until he proved reciprocity between Japan and the Philippines. He also provided a duly authenticated English translation of the Japanese Medical Practitioners Law, whereupon he was admitted to the August 1992 Medical Board E... Case Digest (G.R. No. 166097) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Parties
- Yasuyuki Ota, a Japanese national married to a Filipina, resident in the Philippines for over 10 years, graduated Doctor of Medicine from Bicol Christian College of Medicine on April 21, 1991.
- Completed one-year postgraduate internship at Jose Reyes Memorial Medical Center.
- Application for Licensure
- Filed application to take Philippine medical board examinations; required by PRC to submit an affidavit undertaking that he would not practice until reciprocity with Japan was proven.
- Submitted a duly authenticated English translation of Japan’s Medical Practitioners Law; allowed to take the August 1992 exam and passed.
- Denial of License and Judicial Proceedings
- On March 8, 1993, the Board of Medicine denied his license, citing lack of genuine reciprocity (no Filipino could practice in Japan).
- Ota filed a petition for certiorari and mandamus before the RTC Manila (amended to implead PRC).
- On October 19, 2003, RTC ruled in his favor, ordering issuance of his certificate of registration.
- The Court of Appeals affirmed on November 16, 2004.
- Petitioners (Board and PRC) elevated the case to the Supreme Court via petition for review on certiorari.
Issues:
- Did respondent sufficiently establish reciprocity in the practice of medicine between the Philippines and Japan?
- Is the Board/PRC’s duty to issue a license to a qualified examinee ministerial and enforceable by writ of mandamus?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)