Case Digest (G.R. No. 214435)
Facts:
Professional Regulation Commission v. Dayamon Didato Alo, G.R. No. 214435, February 14, 2022, the Supreme Court Second Division, Hernando, J., writing for the Court.On July 5, 2011, the Board for Professional Teachers (the Board), operating under the Professional Regulation Commission (PRC), formally charged respondent Dayamon Didato Alo with unprofessional and/or dishonorable conduct for allegedly using a falsified Board Resolution No. 671 (dated September 28, 2000) in securing her certificate of registration and professional teacher's license on September 14, 2007. Alo answered with a counter-affidavit asserting she held a B.S. in Elementary Education, had been a public elementary school teacher from 1995 to 2006, and was currently employed as a public elementary school teacher; she denied knowledge of or submission of any Board Resolution No. 671 and maintained she applied under Section 26(c) of Republic Act No. 7836 (RA 7836) which, under certain conditions, allowed registration without examination.
After administrative hearings, the Board rendered a Decision dated September 11, 2012 finding Alo guilty and revoking her certificate and license; its denial of Alo’s motion for reconsideration became final administratively. Instead of appealing to the PRC as provided in PRC internal rules and Section 9(c) of Republic Act No. 8981, Alo filed a petition for review with the Court of Appeals (CA) under Rule 43. The CA required comments from the Board and PRC; both failed to file comments and the CA submitted the case for decision. On February 12, 2014 the CA granted Alo’s petition, reversed the Board’s decision and exonerated her, reasoning that the prosecution failed to present either the alleged falsified or the original Board Resolution No. 671 and that the Board improperly applied a disputable presumption; the CA also held Alo was not apprised of a prescriptive/qualification ground so due process was violated. The Board and PRC filed a motion for reconsideration with the CA attaching an original c...(Subscriber-Only)
Issues:
- Did the Court of Appeals have jurisdiction to directly review the Board’s September 11, 2012 decision?
- Did respondent Alo exhaust available administrative remedies such that the CA properly proceeded, or should the petition have been dismissed for lack of cause of action?
- On the merits, did the Board correctly find Alo guilty of using fraud or deceit (falsification) in obtaining her certificate of registration and professi...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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