Facts:
Philippine Registered Electrical Practitioners, Inc. (PREPI) filed on
July 6, 1988 before the
Regional Trial Court of Manila, Branch 1 a petition for
declaratory relief and/or prohibition, assailing the
constitutional validity of
Board of Electrical Engineering Resolution No. 1, Series of 1986. PREPI is an organization composed of professional electrical engineers, associate electrical engineers, assistant electrical engineers, and master electricians, and it acted through several officers and members. The resolution was issued by the Board of Electrical Engineering then headed by respondent
Mederico T. Cortez, and was approved by respondent
Julio Francia, Jr., in his capacity as Commissioner of the Professional Regulation Commission. The resolution adopted
guidelines for the implementation of the
Continuing Professional Education (CPE) Program for electrical engineers, including a requirement that beginning
January 1, 1988, every electrical engineer must earn
CPE credit units before his license could be renewed. To earn the required units, the engineer had to apply for accreditation with the
Institute of Integrated Electrical Engineers of the Philippines (IIEE), and the resolution specified credit unit requirements over a renewal period of three years for different categories of practitioners. The questioned resolution also set out “possible exemptions” from the CPE guidelines, including practitioners reaching the age of sixty, high-ranking government officials, those undergoing post-doctoral studies during the current registration period, practitioners recommended by the PRC or the Board of Electrical Engineering, and other categories reflected in the resolution’s quoted text. PREPI assailed the resolution as violative of the
equal protection and
due process clauses, as well as the constitutional prohibitions against
bills of attainder and
ex post facto laws, and as inconsistent with the constitutional mandate for the protection of workers’ rights. After hearing, the RTC dismissed the petition for lack of merit, holding that PREPI failed to establish a clear and unequivocal constitutional or statutory violation and noting that reasonable doubts must be resolved in favor of the validity of the questioned issuance. PREPI appealed to the Supreme Court on pure questions of law, arguing essentially that the Board lacked authority to issue the resolution and that, even if it had authority, the resolution was constitutionally infirm. During the pendency of the case, the Court observed that the constitutional inquiry became
moot in light of later supervening measures: on
July 25, 1995,
Executive Order No. 266 was issued, institutionalizing CPE programs under the supervision of the PRC and imposing completion of CPE as a
mandatory requirement for the renewal of professional licenses; and thereafter, the PRC issued
Resolution No. 507, Series of 1997, which expressly repealed other PRC and PRB issuances bearing on the implementation of CPE programs. Consequently, the assailed Board resolution, providing guidelines on CPE for electrical engineers, was no longer in effect.
Issues:
Whether the Board of Electrical Engineering had authority to issue
Board Resolution No. 1, Series of 1986, and whether, assuming authority, the resolution violated the Constitution.
Ruling:
Ratio:
Doctrine: