Case Digest (G.R. No. 78164)
Facts:
Tablarin v. Hon. Angelina S. Gutierrez, G.R. No. 78164, July 31, 1987, Supreme Court En Banc, Feliciano, J., writing for the Court.Petitioners Teresita Tablarin, Ma. Luz Ciriaco, Ma. Nimfa B. Rovira, and Evangelina S. Labao sought admission to medical colleges for School Year 1987–1988 but either did not take or did not successfully pass the National Medical Admission Test (NMAT). They challenged the requirement to take and pass the NMAT, which was mandated by MECS Order No. 52, s. 1985 and administered by the private respondent, the Center for Educational Measurement (CEM); the Board of Medical Education, chaired by Secretary Lourdes Quisumbing, was the other public respondent.
On 5 March 1987 the petitioners filed in the Regional Trial Court (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 (f) of Republic Act No. 2382, as amended, and MECS Order No. 52, s. 1985 — specifically to prevent requiring the NMAT as a condition for issuance of certificates of eligibility, to stop accepting applications for the NMAT, and to halt administration of the NMAT scheduled for 26 April 1987 and thereafter. After hearing, the trial court denied the petitioners’ prayer for preliminary injunction on 20 April 1987, and the NMAT proceeded as scheduled.
Petitioners filed a Special Civil Action for Certiorari with the Supreme Court seeking to set aside the trial court’s order denying a preliminary injunction. The constitutional provisions invoked by petitioners included Article II, Sections 11, 13 and 17, and Article XIV, Sections 1 and 5(3) of the 1987 Constitution. The challenged statutory and administrative authorities derive from the Medical Act of 1959 (RA 2382, as amended), which creates the Board of Medical Education and empowers it to prescribe admission requirements and to accept applications and issue certificates of eligibility (functions found in Sections 1, 5(a), 5(f) and 7 of ...(Pro-only)
Issues:
- May a trial court issue a preliminary injunction to enjoin enforcement of Sections 5(a) and 5(f) of RA 2382, as amended, and MECS Order No. 52, s. 1985, pending determination of their constitutionality?
- Do Sections 5(a) and 5(f) of RA 2382, as amended, and MECS Order No. 52, s. 1985 unconstitutionally delegate legislative power?
- Is the NMAT requirement an unfair, unreasonable, or inequitable requirement denying due process or otherwise beyond the State’s police power?
- Does the annual determination of...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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