Case Digest (G.R. No. 78164)
Facts:
In Teresita Tablarin, et al. v. Angelina S. Gutierrez, et al. (G.R. No. 78164, July 31, 1987), the petitioners—Teresita Tablarin, Ma. Luz Ciriaco, Ma. Nimfa B. Rovira, and Evangeline S. Labao—sought admission to various Philippine medical colleges for the 1987–1988 school year. Because they either did not take or did not pass the National Medical Admission Test (NMAT), as required by Republic Act No. 2382 (the “Medical Act of 1959”), as amended, and MECS Order No. 52, series of 1985 (issued by the Minister of Education, Culture and Sports), the Board of Medical Education refused to issue their certificates of eligibility. On March 5, 1987, petitioners filed in the Regional Trial Court (Branch XXXVII, National Capital Judicial Region) a Petition for Declaratory Judgment and Prohibition with a prayer for Temporary Restraining Order and Preliminary Injunction to enjoin enforcement of Sections 5(a) and 5(f) of the Medical Act and MECS Order No. 52, s. 1985. After hearing, the trialCase Digest (G.R. No. 78164)
Facts:
- Background and Petition
- Petitioners (Tablarin, Ciriaco, Rovira, Labao) sought admission into medical colleges for SY 1987–1988 but did not take or pass the NMAT as required by the Board of Medical Education and administered by CEM.
- On March 5, 1987, they filed in the RTC (Branch XXXVII, Manila) a Petition for Declaratory Judgment and Prohibition with prayer for Temporary Restraining Order and Preliminary Injunction to enjoin:
- Enforcement of Section 5(a) and (f) of R.A. 2382, as amended, and MECS Order No. 52, s. 1985, requiring NMAT for certificates of eligibility;
- Acceptance of NMAT applications and administration scheduled April 26, 1987, and future NMATs.
- Proceedings Below
- On April 20, 1987, the RTC denied the petition for preliminary injunction.
- Despite denial, the NMAT was administered as scheduled; petitioners then filed a Special Civil Action for Certiorari in the Supreme Court to annul the RTC order.
- Statutory and Administrative Framework
- Republic Act No. 2382 (Medical Act of 1959), as amended, created the Board of Medical Education with powers under Section 5 including:
- Prescribing requirements for admission into medical colleges (5[a]);
- Accepting applications and issuing certificates of eligibility (5[f]).
- Section 7 of R.A. 2382 prescribed minimum admission requirements: bachelor’s degree, certificate of eligibility, moral character certificates, birth certificate.
- MECS Order No. 52, s. 1985 (Aug. 23, 1985) established the NMAT as a uniform admission test, with annually determined cutoff scores by the Board after consultation with the Association of Philippine Medical Colleges; no certificate or enrollment without required NMAT qualification.
- The private respondent CEM conducted the NMAT in December 1986 and April 1987 for SY 1987–1988 admissions.
Issues:
- Preliminary Injunction
- Whether a writ of preliminary injunction should issue to enjoin enforcement of Section 5(a) & (f) of R.A. 2382, as amended, and MECS Order No. 52, s. 1985, pending resolution of their constitutionality.
- Constitutionality of NMAT Requirement
- Whether the NMAT requirement violates:
- Article II, Sections 11, 13, 17 (state policies on human dignity, youth role, priority to education);
- Article XIV, Section 1 (right to quality education) and Section 5(3) (right to select profession subject to fair, reasonable, equitable requirements).
- Whether Section 5(a) & (f) of R.A. 2382 involve undue delegation of legislative power.
- Whether the NMAT is an unfair, unreasonable, inequitable requirement denying due process.
- Whether annual variation of NMAT cutoff scores violates equal protection.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)