G.R. No. 181277 - Swedish Match Philippines, Inc. vs. Treasurer of the City of Manila

Case Summary (G.R. No. 181277)

Respondent’s Defense and Documentary Assertions

Alo’s counter-affidavit and position paper asserted that she held a B.S. in Elementary Education and had continuous public elementary school service from 1995 to 2006, and was employed subsequently. She maintained she applied for a professional teacher’s license in September 2007 under Section 26(C) of RA 7836 (registration without examination for certain incumbent teachers), submitted routine forms and fees at PRC, received the license and related certificates, and never saw, used, or attached any falsified Board Resolution No. 671. She contended PRC personnel could have and should have verified any document and that she enjoyed security of tenure under RA 4670 based on her service.

Board Proceedings and Decision

The Board for Professional Teachers found respondent guilty as charged and revoked her certificate of registration and license (Sept. 11, 2012). The Board’s decision ordered surrender of registration documents and prohibited practice of the profession. Alo’s motion for reconsideration before the Board was denied. The Board’s factual findings included the observation that Alo had written the notation “671 s’2000 E/C” on the dorsal portion of the Registry Book entry (Serial No. RS-AAA 0080206), implying representation that she was included in Board Resolution No. 671, despite the authentic resolution’s list not containing her name.

Court of Appeals’ Ruling and Reasoning

The CA granted Alo’s Rule 43 petition and reversed the Board. The CA found the prosecution did not present the alleged falsified Board Resolution No. 671 nor the original authentic resolution as part of the evidence during the administrative proceedings, thereby failing to prove the corpus delicti of falsification or Alo’s participation in such falsification. The CA also concluded the Board improperly relied on a disputable presumption under Rule 131 §3(j) to infer ownership/possession and thus culpability. Finally, the CA held that because the Board later asserted Alo’s registration had prescribed under BPT Resolution No. 600-1997 and RA 7836, this ground was not in the formal charge and thus Alo was not apprised of it, giving rise to denial of due process as to the qualification/prescriptive issue.

Questions Presented to the Supreme Court

The Supreme Court identified two principal issues: (1) whether the CA had jurisdiction to directly review the Board’s decision (given PRC’s internal appellate mechanism); and (2) whether the Board correctly found Alo guilty of falsification and properly revoked her certificate of registration and license.

Jurisdictional Analysis — CA’s Authority under Rule 43 and BP 129

The Court held that the CA had jurisdiction to entertain a Rule 43 petition from the Board’s final administrative decision. The Court examined BP 129 (as amended) and Section 1, Rule 43 of the Rules of Court, which confer exclusive appellate jurisdiction upon the CA over final orders and resolutions of quasi-judicial agencies in the exercise of quasi-judicial functions. The PRC’s internal appeal procedure (e.g., RA 8981 §9(c) and PRC Resolution No. 2013-775) does not legally divest the CA of its statutory appellate jurisdiction; there is no law granting PRC exclusive appellate jurisdiction or expressly excluding Board decisions from CA review under Rule 43. Thus the CA’s exercise of jurisdiction was proper.

Quasi‑Judicial Character of the Board for Professional Teachers

The Court found the Board exercised quasi-judicial functions—investigating facts, holding hearings, issuing subpoenas, and making determinations affecting private rights—and therefore its decisions fall within the CA’s Rule 43 ambit. The Board’s adjudicative role in professional disciplinary matters places its final decisions within the class of rulings the CA may review.

Doctrine of Exhaustion of Administrative Remedies and Its Application

Despite affirming the CA’s jurisdiction, the Supreme Court determined that Alo failed to exhaust administrative remedies because she bypassed the PRC’s internal appeal mechanism (the 15-day non-extendible appeal period to the Commission) and directly filed a Rule 43 petition with the CA. The Court emphasized the doctrine’s rationale—to allow administrative bodies to correct errors, use specialized expertise, and avoid premature judicial intervention—and noted that recognized exceptions to exhaustion (e.g., estoppel, patently illegal acts, unreasonable delay, questions purely legal, urgent judicial intervention, lack of adequate remedy) did not apply. Because Alo filed directly with the CA without justification while still within the reglementary period, her petition should have been dismissed for lack of cause of action under the doctrine of exhaustion and primary jurisdiction.

Merits Considered in the Interest of Substantial Justice

Although dismissal for failure to exhaust was warranted, the Court proceeded to consider the merits to render substantial justice. On substantive review, the Court concluded Alo was not qualified to obtain registration without examination under Section 26(C) of RA 7836 because the basis for incumbency was reckoned as of December 16, 1994. The Board’s implementing BPT Resolution No. 600-1997 required incumbency as of that date and provided deadlines (extended to September 19, 2000) for registration; failure to register by that deadline forfeited the privilege. Alo graduated and commenced teaching service in 1995 and applied only in September 2007—well beyond the cutoff and the extended deadline—so she could not be deemed an eligible applicant under Section 26(C) and related BPT resolution.

Falsification and Misrepresentation Findings Sustained by Substantial Evidence

Separately, the Court found that even if the prosecution had not formally introduced an alleged falsified copy of Board Resolution No. 671 into evidence at the administrative hearing, the Board’s finding that Alo misrepresented her qualifications was supported by substantial evidence. The Board relied on the registry entry notation “671 s’2000 E/C,” which the Court interpreted as an affirmative representation by Alo that she was included in Board Resolution No. 671. Because the authentic Board Resolution did not list her, the notation and the attendant unexplained discrepancy permitted reasonable inferences: either Alo relied on a forged resolution or she deliberately misrepresented her qualifications to obtain registrat

Case Syllabus (G.R. No. 181277)

Procedural History

Petition for review on certiorari under Rule 45 filed before the Supreme Court from the Court of Appeals (CA) Decision dated February 12, 2014 and CA Resolution dated September 12, 2014 in CA-G.R. SP No. 129993 (G.R. No. 214435, February 14, 2022).
Formal administrative charge lodged on July 5, 2011 before the Board for Professional Teachers (Board) under the Professional Regulation Commission (PRC), alleging use of a falsified Board Resolution No. 671 dated September 28, 2000 in obtaining a certificate of registration and professional license (unprofessional/dishonorable conduct).
Board rendered Decision on September 11, 2012 finding respondent Alo guilty and revoking her certificate of registration and professional license; respondent’s motion for reconsideration was denied by the Board.
Respondent Alo did not appeal to the PRC but directly filed a petition for review with the Court of Appeals under Rule 43 (petition filed May 2, 2013).
CA issued a Minute Resolution on September 3, 2013 requiring Board/PRC comments; Board and PRC failed to file comments and the CA submitted the case for decision without comment.
CA Decision dated February 12, 2014 granted Alo’s petition for review, reversed and set aside the Board’s Decision, and exonerated Alo.
Board and PRC filed motion for reconsideration with the CA attaching an original copy of Board Resolution No. 671; CA denied the motion in a Resolution dated September 12, 2014.
PRC filed certiorari petition to the Supreme Court; Supreme Court resolved the case by Decision dated February 14, 2022.

Factual Background

Respondent Dayamon Didato Alo holds a Bachelor of Science in Elementary Education and worked as a public elementary school teacher at Kalanganan Elementary School from 1995 to 2006; she was, at the time of the proceedings, a public school teacher at Tambo Cadayonan Elementary School, Pantar District, Pantar, Lanao del Norte.
Alo was not a passer of the licensure examination for professional teachers.
In September 2007, Alo went to the PRC Head Office in Manila to apply for a Professional Teacher’s License claiming entitlement under Section 26(C) of Republic Act No. 7836 (registration without examination under specified conditions).
Alo alleged she was given application forms, paid fees, and a few days later was issued a professional identification card, certificate of good standing, and a certificate of membership in the National Organization of Professional Teachers, Inc.
The formal administrative accusation alleged that Alo used a falsified Board Resolution No. 671 dated September 28, 2000 when she registered on September 14, 2007; the original Board Resolution No. 671 did not contain her name among those to be registered without examination.
Alo maintained she never submitted or knew of Board Resolution No. 671, argued her registration was founded on Section 26(C) of RA 7836, and questioned how PRC personnel could have been defrauded if a falsified document had been used.
Alo invoked security of tenure under Section 5 of RA 4670 ("The Magna Carta for Public School Teachers") as part of her factual assertions.
Record shows that when filling out the Registry Book for Teachers (Serial No. RS-AAA 0080206), Alo wrote the notation “671 s’2000 E/C” at the dorsal portion under Board Res./Approved Letter (Number & Date).
The special prosecutor initially failed to present either an alleged falsified copy of Board Resolution No. 671 or the authentic/original copy of Board Resolution No. 671 during the administrative proceedings before the Board.

Issues Presented

Whether the Court of Appeals had jurisdiction to directly review the Board’s September 11, 2012 Decision, considering the PRC’s claimed appellate authority over Board decisions.
Whether the Board correctly found respondent Alo guilty of falsification and unprofessional/dishonorable conduct and properly revoked her certificate of registration and professional license.

Court of Appeals’ Findings and Rationale

CA granted Alo’s petition for review and reversed the Board’s decision, exonerating Alo.
CA found the evidence on record utterly insufficient to sustain the Board’s finding of fraud or falsification: the special prosecutor failed to present the alleged falsified Board Resolution No. 671 and failed to produce the authentic/original copy; these documents were not part of the record.
CA credited Alo’s assertion that she never knew of the existence of Board Resolution No. 671 and her assertion that she never falsified it.
CA concluded the prosecutor failed to prove both the falsification and Alo’s authorship of any falsified document, and that the corpus delicti of the alleged falsification was not presented.
CA held the Board erred in applying the disputable presumption under Rule 131, Section 3(j) of the Rules of Court (possession/ownership presumption) because Alo was not accused of falsifying her license but of submitting an alleged falsified Board Resolution; since the license itself was authentic, the presumption was misapplied.
CA also found that the Board’s alternative assertion that Alo’s right to apply had prescribed under Board Resolution No. 600, Series of 1997 (BPT Resolution 600-1997) was not part of the formal charge against her; hence, the CA deemed Alo was not apprised of that ground for revocation and concluded there was a denial of due process on that basis.
CA thus exonerated Alo.

Supreme Court: Jurisdictional Analysis

Supreme Court held that the Court of Appeals has appellate jurisdiction over final decisions, resolutions, orders of quasi-judicial agencies under Section 9(3) of Batas Pambansa Blg. 129 (as amended) and Rule 43 of the Rules of Court; Rule 43’s list of quasi-judicial agencies is not exclusive.
The Board for Professional Teachers is vested with quasi-judicial powers under Section 9(c) of RA 8981 (power to hear and investigate cases, issue summons/subpoenas, and render decisions that bec