A.C. No. 242-J - Tobias vs. Ericta

Republic Act No. 9266 (Architecture Act of 2004) mandates integration of the architecture profession into one national organization, to be accredited by the Board of Architecture (Board) and approved by the Professional Regulations Commission (PRC), and registered with the Securities and Exchange Commission (SEC).
RA 9266 provides that every registered architect becomes an automatic member of the Integrated and Accredited Professional Organization of Architects (IAPOA) upon payment of required fees and dues; membership in other associations remains permissible.

On May 19, 2004, UAP petitioned the Board and PRC for accreditation as the IAPOA under Section 40, RA 9266 and PRC Resolution No. 2004-179.
On June 23, 2004, the Board issued Resolution No. 03, s. 2004 granting UAP’s accreditation, later approved by PRC.
On April 27, 2005, the Board issued Resolution No. 02, s. 2005 requiring architects to submit UAP membership certificates and dues receipts before issuance or renewal of registration and ID cards.
On June 19, 2015, the Board issued Resolution No. 05, s. 2015 requiring new licensure examinees to present UAP dues receipts before registration.

On August 28, 2015, petitioner J. Paul Q. Octaviano filed in the RTC-Manila a Petition for Declaratory Relief seeking to invalidate Resolutions Nos. 03-2004, 02-2005, and 05-2015 for (a) violating RA 9266, (b) equal protection clause, and (c) invalid delegation of legislative power.
RTC-Manila Branch 7 dismissed the petition on August 4, 2016, upholding the validity of the three resolutions.
The Court of Appeals (CA) affirmed the RTC decision on March 2, 2018, and denied reconsideration on May 9, 2018, finding Octaviano had standing and ripeness but that the resolutions complied with RA 9266 and constitutional requirements.
Octaviano filed this Petition for Review on Certiorari before the Supreme Court.

Whether Octaviano’s petition for declaratory relief meets the requisites of a justiciable controversy: actual controversy, legal interest (locus standi), and ripeness.

Whether Resolution No. 03, s. 2004 (UAP accreditation) contravenes Section 40, RA 9266, and the equal protection clause.
Whether Resolution Nos. 02, s. 2005 and 05, s. 2015 validly exercise the Board’s and PRC’s rule-making power or amount to an invalid delegation of legislative power and impair architects’ vested rights.