Case Digest (G.R. No. 77372)
Facts:
Lupo L. Lupangco, et al. v. Court of Appeals and Professional Regulation Commission, G.R. No. 77372, April 29, 1988, Supreme Court First Division, Gancayco, J., writing for the Court.Petitioners are examinees preparing for the licensure examinations in accountancy; respondent is the Professional Regulation Commission (PRC). On or about October 6, 1986 the PRC issued Resolution No. 105 as part of its “Additional Instructions to Examinees,” which forbade any examinee from attending review classes, briefings or the like, or from receiving hand-outs, review materials or tips from review centers, schools, reviewers, instructors or their employees during the three days immediately preceding each examination day; violations would be sanctioned under Sec. 8, Art. III of the Commission’s Rules and Regulations.
On October 16, 1986 petitioners filed with the Regional Trial Court (RTC) of Manila, Branch XXXII, a complaint for injunction (with a prayer for preliminary injunction) seeking to enjoin PRC from enforcing Resolution No. 105 and to have it declared unconstitutional. PRC moved to dismiss on the ground that the RTC lacked jurisdiction. In an order dated October 21 (date as in record), the RTC declared it had jurisdiction and enjoined PRC from enforcing Resolution No. 105 as unconstitutional.
PRC sought relief in the Court of Appeals (CA) by filing a petition for nullification of the RTC order; on January 13, 1987 the CA granted the petition in CA-G.R. SP No. 10591, declared the RTC order null and void, and directed dismissal of Civil Case No. 86-37950 for want of jurisdiction. The CA rested its ruling on the premise that the PRC is a co‑equal body with the RTC and relied on ...(Subscriber-Only)
Issues:
- May the Regional Trial Court exercise jurisdiction to review and enjoin enforcement of a rule or resolution issued by the Professional Regulation Commission, or is the PRC “co‑equal” with the RTC so that the RTC lacks jurisdiction?
- Is Resolution No. 105 a valid exercise of the PRC’s authority, i.e., may the PRC lawfully prohibit examinees from attending review classes or receiving review materials during the three days...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)