G.R. No. L-25135 - Philippine Medical Association vs. Board of Medical Examiners

Petitioner Philippine Medical Association (PMA) filed an original action for certiorari and mandamus against the Board of Medical Examiners (Board) and respondent Jose Ma. Torres.
The purpose was to annul a Board resolution and a certificate issued allowing Torres to practice medicine in the Philippines without taking the required medical licensure examination.

Jose Ma. Torres is a Spanish national and a member of the Claretian Missionaries.
He graduated from the University of Barcelona, Spain, with the degree of Licentiate of Medicine and Surgery, allowing him to practice medicine in Spain.

On January 21, 1955, under Section 771(e) of the Revised Administrative Code, he was granted special authority to practice medicine in Lamitan, Basilan City, due to the lack of qualified physicians there.
This authority was revoked and restored multiple times between 1960 and 1964 following administrative evaluations and Board recommendations.

On April 6, 1965, upon Torres’ motion for reconsideration, the Board issued Resolution No. 25 granting him a certificate to practice medicine in the Philippines without examination, approved by the President.
The Board cited the Treaty on the Validity of Academic Degrees and the Exercise of the Professions between the Philippines and Spain (1949) as the legal basis.

PMA wrote to the Board requesting reconsideration based on Republic Act No. 2882 (Medical Act of 1959), which requires passing the medical exam before practice.
The Board Chairman replied that the final decision was under the President’s authority.
Consequently, on October 18, 1965, PMA filed the present action alleging that the Board had exceeded its authority by issuing the certificate without requiring the examination.

Respondents admitted the factual background but denied the legal conclusions, emphasizing the Treaty’s applicability.
They argued that PMA lacked sufficient interest and had not exhausted administrative remedies.
Cited precedents (Costas v. Aldanese; Almario v. City Mayor) to support the position that PMA had no cause of action.

The Court distinguished those precedents, noting they were mandamus cases by private individuals lacking special interest.
The Court found PMA had legal interest as an association representing physicians.
The Court also held administrative remedies’ exhaustion rule did not apply since the contested resolution was approved by the President.

Whether the Board of Medical Examiners could validly issue a certificate allowing a Spanish graduate and national, Jose Ma. Torres, to practice medicine in the Philippines without passing the prescribed medical examination under Republic Act No. 2882.
Whether the Treaty on the Validity of Academic Degrees and the Exercise of the Professions between the Philippines and Spain exempts holders of Spanish medical degrees from taking the Philippine medical licensure examination.
Whether the Philippine Medical Association had sufficient interest or cause of action to assail the Board’s resolution and the certificate issued to Torres.
Whether the petitioner’s failure to exhaust administrative remedies barred the present suit.