G.R. No. 214435 - Professional Regulation Commission vs. Alo

Case Summary (G.R. No. 214435)

Factual Background

Respondent Alo graduated with a Bachelor of Science in Elementary Education and worked as a public elementary school teacher from 1995 to 2006 and later at Tambo Cadayonan Elementary School. She applied for registration as a professional teacher at the PRC in September 2007 purportedly under Section 26(C) of RA 7836, which allows certain incumbent teachers to obtain certificates of registration and licenses without examination. Alo alleged that she was issued a professional identification card and related certificates after submitting application forms and fees. The Board for Professional Teachers later charged Alo with unprofessional and dishonorable conduct for allegedly using a falsified Board Resolution No. 671 dated September 28, 2000 in obtaining her certificate of registration and professional license.

Respondent’s Defense and Submissions

Alo denied knowledge of the existence of Board Resolution No. 671 and asserted that she never attached such resolution to her registration application. She relied on her long teaching service and her belief that she qualified under Section 26(C) of RA 7836 to support registration without examination. Alo filed a counter-affidavit and a position paper in lieu of personal appearance. She challenged the prosecution to produce the alleged falsified document and the PRC records of her application. Alo also invoked security of tenure under RA 4670 as part of her defense.

Administrative Proceedings Before the Board

The Board conducted hearings and received Alo’s counter-affidavit and position paper. On September 11, 2012, the Board found Alo guilty of the charged unprofessional and dishonorable conduct and revoked her certificate of registration and license as a professional teacher. The Board ordered surrender of her credentials and prohibited her from practicing pending criminal prosecution. The Board thereafter denied Alo’s motion for reconsideration.

Court of Appeals Proceedings and Ruling

Alo filed a petition for review directly with the Court of Appeals under Rule 43. The CA required comments from the Board and the PRC, but the latter failed to file comments within the reglementary period. On February 12, 2014, the CA granted Alo’s petition, reversed the Board’s September 11, 2012 Decision, and exonerated Alo. The CA concluded that the evidence was insufficient to sustain a finding of falsification because the special prosecutor did not present the alleged falsified Board Resolution No. 671 nor the original board resolution as evidence. The CA also held that the Board improperly applied the disputable presumption in Rule 131, Section 3(j) and that Alo’s right to due process was violated because the Board had not charged her with lack of qualification under Section 26(C) of RA 7836 as an independent ground for revocation.

Motion for Reconsideration in the Court of Appeals

The Board and the PRC filed a motion for reconsideration in the CA and attached a copy of the original Board Resolution No. 671. The CA denied the motion for reconsideration on September 12, 2014, affirming its prior decision that the record was insufficient to support the Board’s finding of falsification and that Alo had been denied due process on the qualification issue.

Issues Presented to the Supreme Court

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

Jurisdictional Analysis and Holding on CA Competence

The Supreme Court held that the CA had jurisdiction to entertain a petition under Rule 43 because the Board for Professional Teachers exercised quasi-judicial functions under Section 9(c) of RA 8981 and thus its final decisions fall within the appellate jurisdiction of the Court of Appeals pursuant to Batas Pambansa Bilang 129, as amended. The Court explained that neither the statute nor PRC rules conferred exclusive appellate jurisdiction on the PRC to the exclusion of the CA. The Court cited the definition of a quasi-judicial agency and identified the Board’s investigatory and adjudicatory powers as falling squarely within that concept. Consequently, the CA’s jurisdiction to review the Board’s September 11, 2012 Decision under Rule 43 was proper.

Doctrine of Exhaustion of Administrative Remedies and Dismissal Requirement

Although the CA had jurisdiction, the Supreme Court concluded that Alo failed to exhaust administrative remedies because she did not appeal the Board’s decision to the PRC within the fifteen-day reglementary period prescribed by the PRC’s implementing rules and by Section 9(c) of RA 8981. The Court applied the doctrine of exhaustion of administrative remedies and primary jurisdiction and emphasized its rationale: to afford administrative agencies the opportunity to correct their own errors and to allow specialized adjudicators to exercise their expertise. The Court observed that none of the recognized exceptions to the doctrine applied in this case. Because Alo filed a direct Rule 43 petition without first seeking PRC review and without justifying non-exhaustion, the Court found that the CA should have dismissed the petition for lack of cause of action.

Consideration of the Merits in the Interest of Substantial Justice

The Supreme Court proceeded to address the merits for substantial justice. It held that Alo was not qualified to obtain registration under Section 26(C) of RA 7836 because incumbency under that provision was reckoned as of December 16, 1994, while Alo graduated in April 1995 and commenced teaching in 1995. The Court further explained that BPT Resolution No. 600-1997 extended the registration deadline to September 19, 2000 and provided that failure to register by that date forfeited the privilege to practice the teaching profession. Alo applied for registration in September 2007, seven years after the deadline, and therefore had forfeited the privilege and could only register by taking and passing the licensure examination, which she did not.

Falsification Finding and Evidentiary Basis

On the falsification charge, the Supreme Court found that substantial evidence supported the Board’s finding. The Court acknowledged that the special prosecutor initially failed to present the alleged falsified copy of Board Resolution No. 671 during the administrative hearings. Nonetheless, the original Board Resolution No. 671, later

Case Syllabus (G.R. No. 214435)

Parties and Procedural Posture

Professional Regulation Commission was the petitioner before this Court and was impleaded with the Board for Professional Teachers in the proceedings below.
Dayamon Didato Alo was the respondent who was formally charged before the Board for Professional Teachers on July 5, 2011 for unprofessional and/or dishonorable conduct for allegedly using a falsified Board Resolution No. 671 to obtain a certificate of registration and professional license.
The Board for Professional Teachers rendered a Decision on September 11, 2012 finding Alo guilty and revoking her certificate of registration and professional license.
Alo filed a petition for review with the Court of Appeals under Rule 43 of the Rules of Court, which the CA granted in a February 12, 2014 Decision exonerating her.
The Board and the PRC moved for reconsideration before the CA and attached an original copy of Board Resolution No. 671, but the CA denied the motion in its September 12, 2014 Resolution.
The PRC filed a petition for review on certiorari under Rule 45 with this Court seeking to set aside the CA decisions and to reinstate the Board’s September 11, 2012 Decision.

Key Factual Allegations

Alo claimed continuous public elementary school service from 1995 to 2006 and affirmed a Bachelor of Science in Elementary Education degree.
Alo asserted that she applied for registration at the PRC in September 2007 under Section 26(C) of RA 7836, paid fees, and was issued a professional identification card and supporting documents.
The formal charge alleged that Alo used a falsified Board Resolution No. 671 dated September 28, 2000 when she registered on September 14, 2007.
The prosecution at the Board hearing did not present the alleged falsified Board Resolution No. 671 nor the original Board Resolution as part of the record.
The registry book, however, contained a handwritten notation by Alo reading “671 s’2000 E/C” on the dorsal portion under Board Res./Approved Letter (Number & Date).
The original Board Resolution No. 671 attached later to the motion for reconsideration showed a list of teachers excluded Alo’s name.
Alo filed her CA petition on May 2, 2013 and did not appeal to the PRC within the fifteen-day reglementary period.

Statutory Framework

RA 7836, Section 26 governs registration and exceptions for professional teachers and sets incumbency and time limits for registration without examination.
RA 8981, Section 9(c) vests the various professional regulatory boards with authority to hear and investigate cases and prescribes that their decisions become final subject to appeal to the Commission.
Batas Pambansa Blg. 129 Section 9 and Rule 43 of the Rules of Court define the Court of Appeals’ exclusive appellate jurisdiction over final decisions of quasi-judicial agencies.
Rule 131, Section 3(j) of the Rules of Court contains a presumption regarding possession of things taken in the doing of a recent wrongful act.
BPT Resolution No. 600, s. 1997 fixed and extended the deadline for registration under Section 26(C) of RA 7836 to September 19, 2000.
RA 4670, Section 5 (The Magna Carta for Public School Teachers) contains a provision on permanent appointment after ten years of continuous service which Alo invoked in her defense.

Issues Presented

Whether the Court of Appeals had jurisdiction to directly entertain the petition for review of the Board’s decision instead of the PRC.
Whether the Board correctly found Alo guilty of falsification or fraud in securing her certificate of registration and professional license and properly revoked the same.

Court of Appeals Rationale

The CA held the evidence on record was insufficient to prove falsification because the special prosecutor did not present the alleged falsified Board Resolution No. 671 nor the original resolution at the administrative hearing.
The CA gave credence to Alo’s denial of knowledge of Board Resolution No. 671 and found the corpus delicti of falsification unproved.
The CA criticized the Board’s reliance on the disputable presumption under Rule 131, Sec. 3(j) as wrongly applied to a case concerning an alleged falsified supporting document rather than a falsified license.
The CA concluded that because the issue of prescription under BPT Resolution 600-1997 was not pleaded in the formal charge, Alo was not apprised of that