Case Summary (G.R. No. 144681)
Administrative Charges and Investigation
On June 7, 1993, the Board issued Resolution No. 19 to withhold registration pending inquiry. By July 21, 1993, Resolution No. 26 formally charged examinees with immorality, dishonesty, fraud, and deceit, and filed Administrative Case No. 1687 to determine respondents’ moral and mental fitness under Sections 8, 9, 20, and 22 of RA 2382.
Mandamus Action Before the RTC
Respondents filed Civil Case No. 93-66530 seeking a writ of mandamus and preliminary injunction to compel PRC to administer oaths and register them as physicians. The RTC granted preliminary mandatory injunction on July 28, 1993.
Early Appellate Proceedings on Preliminary Injunction
Petitioners secured a preliminary writ of certiorari from the Court of Appeals in CA-G.R. SP No. 31701 (Oct 21, 1993), nullifying the RTC injunction. The Supreme Court denied further review in G.R. No. 112315 (May 23, 1994), affirming that licensing may become discretionary when moral fitness is in doubt.
Trial Court Judgment on Mandamus
Following procedural delays and waiver of cross-examination rights by petitioners, the RTC on December 19, 1994, granted the writ of mandamus, ordering PRC to administer the physician’s oath and register qualifying examinees, without prejudice to administrative discipline.
Subsequent Appeals and Consolidation
Petitioners appealed to the Court of Appeals (CA-G.R. SP No. 34506) and separately to the Supreme Court (G.R. Nos. 117817 & 118437). The Court of Appeals granted certiorari to vacate certain RTC orders but did not dismiss Civil Case No. 93-66530. The Supreme Court later dismissed the petitions in 1998 as moot or pending before the appellate court.
Final Appellate Decision on Merits
In CA-G.R. SP No. 37283, the Court of Appeals (May 16, 2000) affirmed the RTC’s judgment, holding that respondents satisfied statutory requirements under RA 2382 and were entitled to oaths and registration.
Issue: Proper Use of Mandamus and Board Discretion
The sole issue before the Supreme Court was whether respondents had a clear, ministerial right to registration mandating issuance of a writ of mandamus, despite ongoing administrative proceedings on moral fitness.
Statutory Interpretation of the Medical Act
Section 20 of RA 2382 uses the imperative “shall” for issuance of certificates to those who “satisfactorily complied,” but must be read with Section 22 granting the Board power to investigate and disapprove registrations pending determination of moral or mental fitness.
Licensing as a Privilege Subject to Police Power
The Court reaffirmed that medical licensure is a privilege, not an absolute right, and may be regulated under the State’s police power. Where doubt exists about the integrity of examination result
...continue readingCase Syllabus (G.R. No. 144681)
Facts
- Respondents were graduates of Fatima College of Medicine who passed the February 1993 Physician Licensure Examination.
- The Board of Medicine observed unusually high and tightly clustered scores in Biochemistry and Obstetrics-Gynecology among Fatima examinees.
- A statistical report by Fr. Bienvenido F. Nebres concluded that such clustering could only arise from an “unusual reason.”
- The NBI investigation suggested early access to test questions by Fatima examinees.
- On June 7, 1993, the Board issued Resolution No. 19 withholding registration; on July 21, 1993, Resolution No. 26 charged respondents with immorality, dishonesty, fraud, and deceit, and recommended nullification of their test results.
Trial Court Proceedings
- Civil Case No. 93-66530 (RTC Manila, Branch 52): respondents filed a petition for mandamus with prayer for preliminary mandatory injunction to compel PRC to administer physician’s oath and register them.
- RTC granted the injunction; PRC secured a writ of certiorari from the Court of Appeals (CA-G.R. SP No. 31701) nullifying that injunction.
- During trial, petitioners’ counsel repeatedly failed to appear, resulting in waiver of cross-examination and denial of motions for reconsideration.
- RTC rendered judgment on December 19, 1994, ordering PRC to administer the oath and register respondents, without prejudice to administrative disciplinary action.
Intermediate Appellate Proceedings
- CA-G.R. SP No. 31701 reaffirmed that the PRC’s action becomes discretionary if moral fitness is in doubt; Supreme Court denied review in G.R. No. 112315 (May 23, 1994).
- PRC’s certiorari in CA-G.R. SP No. 34506 voided certain RTC orders and reinstated petitioners’ right to cross-examine, but did not dismiss Civil Case No. 93-66530.
- Supreme Court consolidated G.R. Nos. 117817 & 118437, dismissed them as moot or pending appeal (July 9, 1998).
- CA-G.R. SP No. 37283 (May 16, 2000) affirmed the RTC decision granting mandamus; denied motion for reconsideration on August 25, 2000.
Issues Presented
- Whether respondents have a clear legal right to mandamus relief despite prior rulings on moral fitness.
- Whether mandamus may issue while Adm. Case No. 1687 (administered by PRC against moral fitne