Case Summary (G.R. No. 239350)
Petitioner
J. Paul Q. Octaviano challenged the Board’s Resolutions No. 03, Series of 2004; No. 02, Series of 2005; and No. 05, Series of 2015, alleging they exceed statutory authority, violate equal protection and constitutional non-delegation principles, and contravene Republic Act No. 9266.
Respondents
• Board of Architecture: vested by RA 9266 with power to prescribe rules and regulations to implement the Architecture Act.
• PRC: reviews and approves Board resolutions, enforces professional regulatory policies under RA 8981.
• UAP: petitioned for and received accreditation as the Integrated and Accredited Professional Organization of Architects (IAPOA).
Key Dates
– March 17, 2004: RA 9266 (Architecture Act) enacted, mandating integration of architects into one national organization.
– May 19, 2004: UAP files petition for accreditation under Sec. 40, RA 9266 and PRC Res. 2004-179.
– June 23, 2004: Board issues Res. 03, S. 2004 granting UAP accreditation; PRC approves.
– April 27, 2005: Board issues Res. 02, S. 2005 requiring UAP membership certificate and dues receipt before registration or renewal.
– June 19, 2015: Board issues Res. 05, S. 2015 requiring dues receipt for licensure registration.
– August 28, 2015: Octaviano files declaratory relief in RTC Manila.
– August 4, 2016: RTC dismisses petition; upholds resolutions.
– March 2, 2018: Court of Appeals affirms.
– May 9, 2018: CA denies reconsideration.
– June 6, 2018: Petition for review filed with the Supreme Court.
– August 22, 2023: SC issues decision.
Applicable Law
– 1987 Philippine Constitution (decision date post-1990).
– Republic Act No. 9266 (Architecture Act of 2004).
– Republic Act No. 8981 (PRC Modernization Act of 2000).
– Rule 63, Rules of Court (declaratory relief).
– Jurisprudence on justiciability, administrative rule-making, non-delegability of legislative power, equal protection, police power.
Factual Background
Section 40, RA 9266 mandates integration of architects into one SEC-registered non-stock national organization accredited by the Board and approved by PRC. UAP applied and secured this accreditation (Res. 03, S. 2004). The Board then issued:
• Res. 02, S. 2005: requires architects to submit UAP membership certificate and dues receipt before issuance/renewal of registration and ID cards.
• Res. 05, S. 2015: requires successful licensure examinees to present dues payment receipt prior to registration.
Procedural History
Octaviano filed for declaratory relief in the RTC, claiming violations of RA 9266, equal protection, and non-delegation. The RTC dismissed; the CA affirmed on both procedural (justiciability) and substantive grounds. Octaviano elevated the case to the Supreme Court.
Issues
- Whether the petition meets justiciability requirements (actual controversy, legal interest, ripeness).
- Whether Resolutions Nos. 03 (2004), 02 (2005), and 05 (2015) are valid and constitutional under RA 9266 and the 1987 Constitution.
Justiciability
The Court held that:
• There is an actual and adversarial controversy: Octaviano’s rights to associate and practice architecture are directly affected by ongoing obligations under the challenged resolutions.
• He has legal interest (locus standi) in contesting rules that condition his professional registration and licensure.
• The issues are ripe, as the resolutions impose continuous, enforceable requirements.
Administrative Rule-Making and Delegation
Under the 1987 Constitution, legislative power is non-delegable except for subordinate rule-making. RA 8981 and RA 9266 expressly authorize PRC and the Board to promulgate implementing rules and regulations (“supplementary legislation”) within statutory confines and standards.
Validity of Accreditation Resolution (Res. 03, S. 2004)
Octaviano argued that RA 9266 required creation of a new organization and a sequential procedure including post-accreditation SEC registration. The Court found Section 40 merely mandates accreditation of “one national organization” already SEC-registered; no requirement for a newly formed entity or additional steps. PRC Resolution 2004-178 confirms that SEC registration is a precondition t
Case Syllabus (G.R. No. 239350)
Factual and Procedural Background
- Republic Act No. 9266 (Architecture Act of 2004) mandated integration of the architecture profession into one integrated and accredited professional organization of architects.
- On May 19, 2004, United Architects of the Philippines (UAP) petitioned the Board of Architecture (Board), PRC for accreditation under Section 40 of RA 9266 and PRC Resolution No. 2004-179.
- The Board issued Resolution No. 03, Series of 2004 (June 23, 2004) granting UAP’s petition; the PRC approved the grant.
- The Board issued Resolution No. 02, Series of 2005 (April 27, 2005), requiring architects to submit proof of UAP membership and payment of dues before issuance or renewal of registration and ID cards.
- The Board issued Resolution No. 05, Series of 2015 (June 19, 2015), requiring successful licensure examinees to present official receipts of UAP dues payment before registration.
- On August 28, 2015, petitioner Octaviano filed a Petition for Declaratory Relief in RTC Manila challenging Resolutions 03/2004, 02/2005 and 05/2015 as violative of RA 9266, the Equal Protection Clause, and as invalid delegations of legislative power.
- The PRC, Board and UAP intervenor–respondent moved to dismiss for lack of legal interest, absence of justiciable controversy, and compliance with law.
- The RTC (August 4, 2016) dismissed Octaviano’s petition, upholding the three resolutions as valid exercises of delegated authority.
- On appeal, the Court of Appeals (March 2, 2018) affirmed the RTC decision on substantive grounds but ruled that a justiciable controversy existed and that Octaviano had locus standi.
- The Court of Appeals denied reconsideration (May 9, 2018). Octaviano filed a Petition for Review on Certiorari in the Supreme Court (June 6, 2018).
Issues
- Whether Octaviano’s Petition for Declaratory Relief satisfies the requisites of justiciability under Rule 63, Rules of Court.
- Whether Board Resolution No. 03, Series of 2004, Resolution No. 02, Series of 2005 and Resolution No. 05, Series of 2015 are valid and constitutional exercises of rule-making authority under RA 9266 and the Constitut