Case Digest (G.R. No. 200015) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Department of Public Works and Highways v. Philippine Institute of Civil Engineers, Inc. and Leo Cleto Gamolo (consolidated with United Architects of the Philippines v. Philippine Institute of Civil Engineers, Inc. and Leo Cleto Gamolo), the issue arose after the DPWH, on October 29, 2004, promulgated the 2004 Revised Implementing Rules and Regulations of Presidential Decree No. 1096 (the National Building Code). The challenged provisions—Section 302, paragraphs 3 and 4—restricted the preparation, signing, and sealing of “architectural documents” exclusively to registered and licensed architects. Thereafter, Leo Cleto Gamolo and the Philippine Institute of Civil Engineers filed a declaratory relief petition in the Regional Trial Court of Manila, seeking to void those paragraphs and to allow civil engineers to prepare, sign, and seal the listed documents. A separate but similar petition was filed by Felipe Cruz Sr. and David M. Consunji in Quezon City. The United Architect Case Digest (G.R. No. 200015) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidation and parties
- Petitions for review on certiorari in G.R. No. 200015 (DPWH) and G.R. No. 205846 (UAP) challenge the Court of Appeals’ January 5, 2012 decision reversing the RTC, which upheld the validity of Sections 302(3) and (4) of the 2004 Revised Implementing Rules and Regulations (2004 RIRR) of PD 1096 (National Building Code).
- Petitioners: Department of Public Works and Highways (DPWH) and United Architects of the Philippines (UAP). Respondents: Philippine Institute of Civil Engineers, Inc. (PICIE) and Leo Cleto Gamolo.
- Statutory framework and rulemaking
- Presidential Decree No. 1096 (PD 1096) – the 1977 National Building Code – originally implemented by Ministry Order No. 57 (1976).
- Republic Act No. 9266 (Architecture Act of 2004), effective April 10, 2004, grants architects exclusive authority over architectural documents.
- On October 29, 2004, DPWH issued the 2004 RIRR, adding Sections 302(3)–(4) to limit preparation, signing, and sealing of architectural documents to architects (with some allowance for interior designers).
- Procedural history
- Gamolo petition filed in the RTC of Manila sought declaratory relief and injunction to nullify Sections 302(3)–(4) and allow civil engineers to prepare and seal documents. A similar Cruz petition was filed in RTC Quezon City. UAP intervened in the Manila RTC.
- RTC of Manila (Jan. 29, 2008) dismissed the petition, upholding the 2004 RIRR. Motion for reconsideration denied (May 4, 2009).
- CA (Jan. 5, 2012) reversed the RTC, declaring Sections 302(3)–(4) void and affirming civil engineers’ right to prepare those documents. CA denied UAP’s motion for reconsideration (Feb. 13, 2013).
- DPWH and UAP separately elevated the case to the Supreme Court, which consolidated the petitions (June 8, 2013).
- Parties’ contentions
- Petitioners argue that the 2004 RIRR validly implements RA 9266, that “architectural documents” classification has basis in Ministry Order No. 57 and RA 9266, and that PD 1096 and RA 544 never authorized civil engineers to seal architectural plans. They assert RA 9266 impliedly repealed conflicting provisions of RA 544 and PD 1096.
- Respondents maintain that PD 1096 (Sections 302 and 308) and RA 544 expressly authorize civil engineers to prepare, sign, and seal architectural-related plans, that RA 9266 did not repeal or limit those rights, and that the classification in the 2004 RIRR unlawfully displaces civil engineers.
Issues:
- Did respondents commit forum shopping?
- Are Sections 302(3) and (4) of the 2004 Revised Implementing Rules valid?
- Does PD 1096 authorize civil engineers to prepare, sign, and seal architectural plans?
- Does RA 544 permit civil engineers to prepare, sign, and seal architectural plans?
- Did RA 9266 modify or repeal RA 544 and PD 1096?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)