Case Digest (G.R. No. 251816)
Facts:
Petitioner Florentina Caoyong Sobrejuanite-Flores applied on May 7, 2015 for registration as a psychologist without examination under the “grandfather” clause of Republic Act No. 10029 after the Professional Regulatory Board of Psychology approved the IRR on November 28, 2012 which defined eligibility, including the requirement of ten (10) years’ practice and completion of at least one hundred (100) hours of updating workshops. The Professional Regulation Commission and the Board denied her application for failing to prove ten (10) years’ service and the required one hundred (100) hours, the Court of Appeals affirmed on May 21, 2019, and petitioner brought this petition for review on certiorari.
Issues:
- Is Section 16(c) of the Implementing Rules and Regulations of RA No. 10029—requiring completion of at least one hundred (100) hours of updating workshops—unconstitutional?
- Was petitioner entitled to registration without examination under Section 16(c) given the evidence she presented?
Ruling:
The Court DENIED the petition and AFFIRMED the Court of Appeals. The Court held that Section 16(c) of the IRR is not unconstitutional. The Court further agreed with the CA and the administrative agencies that petitioner failed to prove she met the ten (10) years’ experience and one hundred (100) hours’ training requirements and thus was not entitled to registration without examination.
Ratio:
The Court found that RA No. 10029 authorized the Board to promulgate IRR and that the IRR satisfied the completeness test and the sufficient standard test because the statute set the fundamental policy to regulate the practice of psychology and protect the public. The additional IRR requirement for one hundred (100) hours of updating workshops was upheld under the State’s police power and the equal protection analysis applying the rational basis test, since the classification between bachelor’s degree holders and graduate-degree holders is germane to the law’s purpose; administrative regulations enjoy a presumption of validity and factual findings of the Board and the CA on petitioner’s credentials were binding absent the recognized exceptions.
Doctrine:
- Administrative regulations duly promulgated under statutory authority have the force of law and enjoy a presumption of constitutionality.
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