Case Digest (G.R. No. L-30642) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 251816, decided on November 23, 2021 under the 1987 Constitution, petitioner Florentina Caoyong Sobrejuanite-Flores sought registration as a psychologist without examination pursuant to Republic Act No. 10029 (Philippine Psychology Act of 2009). Section 16 of the Act allowed certain practitioners to be registered without examination if, on or before June 2, 2010, they possessed specified educational attainments and accrued work experience: (a) a doctoral degree plus three years of practice, (b) a master’s degree plus five years of practice, or (c) a bachelor’s degree plus ten years of practice and “updated professional education.” On November 28, 2012, the Professional Regulatory Board of Psychology promulgated the Implementing Rules and Regulations (IRR). Under Section 16(c) of the IRR, bachelor’s degree holders needed, among other things, to complete 100 hours of updating workshops and training programs within the five years preceding June 2, 2010. Petitioner appli Case Digest (G.R. No. L-30642) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Legislative and Regulatory Framework
- Republic Act No. 10029 (Philippine Psychology Act of 2009)
- Requires passing of a licensure examination to practice psychology.
- Section 16 grants registration without examination within three years for applicants meeting (a) doctoral + 3 years experience, (b) master’s + 5 years, or (c) bachelor’s + 10 years + updated professional education.
- IRR of RA 10029 (Board Resolution No. 003-12, Nov. 28, 2012)
- Implements Section 16: sets cut-off filing until May 21, 2015.
- Defines “professional education in various psychology-related functions” as completion of at least 100 hours of workshops/training in the last five years before June 2, 2010.
- Petitioner’s Application and Administrative Proceedings
- Florentina Caoyong Sobrejuanite-Flores applied on May 7, 2015 for registration without examination under Section 16(c).
- The Board of Psychology (BOP) denied for:
- Only six years work experience as a psychologist (2004–2010) vs. required ten.
- Failure to submit proof of 100 hours of updating workshops/training (2005–2010).
- PRC denied her final appeal and motion for reconsideration affirming the BOP findings.
- Judicial Proceedings
- Petition for Review under Rule 43 filed with the Court of Appeals (CA-G.R. SP No. 150841).
- CA Decision (May 21, 2019):
- Upheld IRR Section 16(c) as valid.
- Affirmed that petitioner failed to prove ten years of experience and 100 hours of workshops.
- Rejected equal protection challenge to the 100-hour requirement.
- Petition for review on certiorari filed with the Supreme Court, arguing that the 100-hour requirement:
- Is an additional condition not found in the statute.
- Violates due process and equal protection.
Issues:
- Did the IRR’s Section 16(c) exceed the legislative delegation under RA 10029 by imposing an extra 100-hour requirement not in the statute?
- Does the 100-hour updating training requirement violate:
- The completeness test and sufficient standard test for valid subordinate legislation?
- The constitutional guarantees of due process and equal protection?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)