Case Digest (G.R. No. L-16263) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dr. Jose Cuyegkeng, et al. v. Dr. Pedro M. Cruz (G.R. No. L-16263, July 26, 1960), seven physicians—Drs. Jose Cuyegkeng, Pedro N. Mayuga, Benjamin Roa, Timoteo Alday, Dominador Jacinto, Alejandro Gaerlan and Rosita Rivera-Ramirez—filed a quo warranto petition on November 25, 1959 before the Supreme Court, later amended on December 1, 1959. They alleged that their names appeared on the list of twelve qualified physicians approved and submitted by the Executive Council of the Philippine Medical Association (PMA) to the President, pursuant to section 13 of Republic Act No. 2382 (Medical Act of 1959), for appointment as members of the Board of Medical Examiners. Despite their inclusion, the President appointed Dr. Pedro M. Cruz—whose name was not on that list—alongside five others. The petitioners prayed that their qualifications be recognized, that Dr. Cruz’s appointment be declared null and void, and that he be ousted from office, with a preliminary injunction to bar him from p Case Digest (G.R. No. L-16263) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- On November 25, 1959, petitioners Drs. Jose Cuyegkeng, Pedro N. Mayuga, Benjamin Roa, Timoteo Alday, Dominador Jacinto, Alejandro Gaerlan and Rosita Rivera-Ramirez filed a quo warranto petition against Dr. Pedro M. Cruz, member of the Board of Medical Examiners, praying:
- To declare petitioners duly qualified for appointment and Cruz’s appointment null and void.
- To issue a preliminary injunction barring Cruz from performing board duties (examinations scheduled December 14, 1959).
- On December 3, 1959, the Supreme Court denied the ex parte preliminary injunction.
- Submission of List and Appointment
- Pursuant to Section 13, Republic Act No. 2382 (The Medical Act of 1959), the Executive Council of the Philippine Medical Association submitted on October 16, 1959 a confidential list of twelve “recommendees” for board membership.
- By letter dated November 18, 1959, the Assistant Executive Secretary informed the Council the President would appoint Drs. Cesar Filoteo, Oscar Chacon, Edgardo Caparas, Jose Cocjin, Antonio Guytingco and Pedro M. Cruz as the six board members. Only the first five appeared on the submitted list; Cruz’s name was not included.
- Parties’ Contentions
- Petitioners and intervenors (Executive Council): Section 13’s requirement that the President appoint “from the confidential list” is mandatory; Cruz’s appointment is void.
- Respondent Cruz:
- The list is merely recommendatory and not binding on the President.
- Three petitioners are statutorily unqualified under Section 14 RA 2382.
- Section 15 authorizes reappointment of an incumbent, even if not named on the list.
- Petitioners lack cause of action—they do not claim entitlement to Cruz’s specific office.
Issues:
- Is Section 13 of Republic Act No. 2382 mandatory (binding on the President) or directory (recommendatory)?
- Was the appointment of Dr. Pedro M. Cruz to the Board of Medical Examiners valid?
- Do petitioners and intervenors have a cause of action in quo warranto against Cruz?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)