Case Digest (G.R. No. 174504)
Facts:
In Professional Regulation Commission v. Dayamon Didato Alo, G.R. No. 214435, decided February 14, 2022, respondent Dayamon Didato Alo, a public elementary school teacher since 1995, applied on September 14, 2007 for a Professional Teacher’s License and Certificate of Registration at the PRC under Section 26(C) of Republic Act No. 7836. The Board for Professional Teachers charged her with unprofessional and dishonorable conduct for allegedly using a falsified Board Resolution No. 671 dated September 28, 2000—documenting those entitled to registration without examination—to secure her license, despite her name not appearing on the original resolution. Alo denied knowledge of the resolution, contending she applied on the strength of her teaching service and degree, and that the PRC personnel should have verified authenticity. After a hearing, the Board rendered a September 11, 2012 decision revoking her credentials for fraud. Alo’s motion for reconsideration was denied. BypassingCase Digest (G.R. No. 174504)
Facts:
- Charge and Allegations
- On July 5, 2011, Dayamon Didato Alo was formally charged before the Board for Professional Teachers (Board), under the Professional Regulation Commission (PRC), with unprofessional and/or dishonorable conduct for allegedly using a falsified Board Resolution No. 671 dated September 28, 2000 in obtaining her professional teaching license and certificate of registration on September 14, 2007. The original Resolution No. 671 did not list her among those qualified for registration without examination.
- The charge was predicated on fraud or deceit in securing her credentials under Section 26 of Republic Act (RA) No. 7836.
- Respondent’s Defense
- Alo averred she earned a Bachelor of Science in Elementary Education, served as a public elementary school teacher from 1995 to 2006, and was teaching in Lanao del Norte when she applied for her license in September 2007 under Section 26(C) of RA 7836, which grants registration without examination to incumbent teachers with five years’ service.
- She maintained she never knew of or submitted Resolution No. 671, that PRC personnel issued her professional ID card, certificate of good standing, and membership certificate without requesting any board resolution, and that the PRC could have verified any document it deemed suspicious.
- Administrative Proceedings
- On September 11, 2012, the Board rendered a Decision finding Alo guilty as charged, revoked her certificate and license, and ordered her to surrender her credentials within 15 days. A motion for reconsideration was denied.
- Instead of appealing to the PRC within 15 days, Alo directly filed a petition for review under Rule 43 with the Court of Appeals (CA) on May 2, 2013.
- CA Proceedings and Supreme Court Review
- The CA deemed PRC’s comment waived, and on February 12, 2014, issued a Decision reversing the Board’s finding, exonerating Alo for lack of proof of a falsified resolution and for denial of due process regarding her RA 7836 qualifications.
- A motion for reconsideration, attaching the authentic Resolution No. 671, was denied by the CA on September 12, 2014. The PRC then filed a Rule 45 petition for certiorari with the Supreme Court.
Issues:
- Jurisdiction
- Does the Court of Appeals have jurisdiction to directly review the Board’s September 11, 2012 decision of the PRC?
- Merits of Falsification and Revocation
- Did the Board correctly find respondent guilty of falsification in obtaining her license and certificate, and properly revoke her registration?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)