Case Digest (G.R. No. 113105) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Professional Regulation Commission v. Philippine Society of Mechanical Engineers (PSME), G.R. No. 254282, decided on September 14, 2021, the PSME, represented by its incumbent President Engr. Murry F. Demdam, filed a petition before the Regional Trial Court (RTC) Manila, Branch 6, seeking nullification of PRC Office Order No. 2016-56. This order, issued on February 10, 2016 by Acting Chairperson Angeline T. Chua Chiaco, recognized Engr. Leandro A. Conti as the 2016 PSME National President for the limited purpose of issuing Certificates of Good Standing required for professional identification card renewals. The controversy originated from the PSME’s October 2015 elections, where Engr. Conti lodged protests against alleged irregularities in the Manila Chapter ballots. The PSME Commission on Elections (COMELEC) annulled 999 NCR votes in favor of Demdam’s slate and proclaimed Conti’s group as winners of the Board of Directors seats, subsequently electing Conti as National Presid... Case Digest (G.R. No. 113105) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Context of the PSME Leadership Dispute
- October 21–25, 2015: PSME held elections for its 2016 Board of Directors; Engr. Demdam’s slate initially proclaimed winners.
- October 26, 2015: Engr. Conti filed protest alleging ballot irregularities in the Manila Chapter.
- November 22, 2015: PSME-COMELEC issued Omnibus Resolution annulling 999 NCR votes and declaring Conti’s group as duly elected directors.
- November 25, 2015: PSME-COMELEC conducted officers’ election; Engr. Conti proclaimed National President.
- PRC Recognition and Parallel Litigation
- December 18, 2015: PRC Acting Chairperson issued letter recognizing Conti as 2016 PSME President for issuing Certificates of Good Standing (COGS).
- February 10, 2016: PRC Office Order No. 2016-56 formally directed acceptance of COGS signed by Conti for PIC renewals.
- March 7, 2016: Demdam’s group filed petition for nullity of PRC Office Order No. 2016-56 before RTC Manila-Br. 6.
- November 26, 2015: Conti’s group filed intra-corporate case before RTC Manila-Br. 24 to validate PSME-COMELEC resolutions and election.
- Lower Court and Appellate Proceedings
- August 8, 2016: RTC Manila-Br. 24 declared valid the Omnibus Resolution of November 22, 2015 but voided the November 25 officers’ election (Conti’s presidency).
- August 31, 2017: RTC Manila-Br. 6 granted PRC’s Omnibus Motion to Dismiss nullity petition, ruling it moot and barred by res judicata.
- March 10, 2020: Court of Appeals reversed and remanded for resolution on merits, holding the nullity issue not moot and res judicata inapplicable.
- September 21, 2020: CA denied PRC’s motion for reconsideration.
Issues:
- Primary Issue
- Whether the petition for declaration of nullity of PRC Office Order No. 2016-56 is rendered moot by the RTC Manila-Br. 24 decision voiding Engr. Conti’s election as 2016 PSME National President.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)