Case Digest (G.R. No. 89572)
Facts:
In Department of Education, Culture and Sports v. San Diego (G.R. No. 89572, December 21, 1989), the petitioners are the Department of Education, Culture and Sports (DECS) and the Director of the Center for Educational Measurement, while the private respondent is Roberto Rey C. San Diego, a Bachelor of Science in Zoology graduate from the University of the East. Under MECS Order No. 12, Series of 1972, a student shall be allowed only three chances to take the National Medical Admission Test (NMAT), and after three successive failures, a fourth attempt is forbidden. San Diego took and failed the NMAT three times; his application for a fourth attempt was denied on the basis of this “three-flunk rule.” He petitioned the Regional Trial Court (RTC) of Valenzuela, Metro Manila, under Judge Teresita Dizon-Capulong, for a writ of mandamus to compel his admission to the NMAT, invoking his constitutional rights to academic freedom and to quality education. By agreement, he was allowed toCase Digest (G.R. No. 89572)
Facts:
- Parties and Subject Matter
- Petitioners: Department of Education, Culture and Sports (DECS) and Director of Center for Educational Measurement.
- Private Respondent: Roberto Rey C. San Diego, B.S. Zoology graduate seeking admission to medical education via NMAT.
- Procedural History
- The NMAT “three-flunk rule” (MECS Order No. 12, Series of 1972) limits applicants to three attempts; private respondent failed the NMAT four times and was denied a fifth application.
- Private respondent filed a petition for mandamus in RTC Valenzuela to compel DECS to admit him to the fourth (actually fifth) NMAT, invoking academic freedom and right to quality education.
- With leave of court, he amended the petition to challenge the rule’s constitutionality on grounds of due process and equal protection.
- RTC Branch 172 (Judge Capulong) rendered judgment on July 4, 1989, declaring the three-flunk rule invalid and granting relief.
Issues:
- Entitlement to Re-Examination
- May an applicant who has failed the NMAT three (or more) times validly be barred from further attempts under MECS Order No. 12?
- Does the three-flunk rule unreasonably infringe on a student’s right to choose a course of study and to quality education?
- Constitutional Validity of the Rule
- Does the rule violate due process by being arbitrary or oppressive under the State’s police power?
- Does it breach equal protection by creating unjustifiable distinctions among applicants?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)