Title
Tablarin vs. Gutierrez
Case
G.R. No. 78164
Decision Date
Jul 31, 1987
Petitioners challenged the NMAT requirement for medical school admission, claiming it violated constitutional rights. The Supreme Court upheld its constitutionality, ruling it a valid exercise of state police power to ensure quality medical education and public health.
constitutionality
police power
public health and safety
A

Case Summary (G.R. No. 78164)

Procedural History

Petitioners filed a Petition for Declaratory Judgment and Prohibition with a prayer for Temporary Restraining Order and Preliminary Injunction in the Regional Trial Court seeking to enjoin enforcement of Section 5(a) and (f) of the Medical Act (R.A. No. 2382, as amended) and MECS Order No. 52, s. 1985, and to stop administration of the NMAT scheduled for April 26, 1987. The trial court denied the petition for preliminary injunction on April 20, 1987; the NMAT was administered as scheduled. Petitioners then filed a special civil action for certiorari with the Supreme Court to set aside the trial court’s denial of preliminary injunction.

Statutory Framework — Medical Act of 1959 (R.A. No. 2382, as amended)

The Medical Act’s stated objectives include the standardization and regulation of medical education, examination for registration of physicians, and supervision, control and regulation of the practice of medicine. The statute created the Board of Medical Education, identified its membership (including the Secretary of Education as Chair and representatives from health, higher education, the Medical Board, medical associations and deans), and conferred functions including (a) determining and prescribing requirements for admission into recognized colleges of medicine and (f) accepting applications and issuing certificates of eligibility for admission to medical school, with power to promulgate implementing rules and regulations.

Statutory Admission Requirements

Section 7 of the Medical Act prescribes minimum admission requirements for medical colleges: no conviction for offenses involving moral turpitude; record of completion of a bachelor’s degree; certificate of eligibility for entrance to a medical school from the Board; certificates of good moral character by two former professors in the college of liberal arts; and birth certificate. The statute expressly permits medical colleges to establish additional entrance requirements.

MECS Order No. 52, s. 1985 — Establishment of the NMAT

MECS Order No. 52, s. 1985 established a uniform National Medical Admission Test (NMAT), an aptitude test, as an additional prerequisite for issuance of certificates of eligibility for admission into Philippine medical schools beginning school year 1986–1987. The Order states the NMAT is intended to upgrade selection of applicants and improve medical education quality; the Board, after consultation with the Association of Philippine Medical Colleges, would determine the annual cutoff score; the NMAT rating, together with other admission requirements, would serve as the basis for issuing certificates of eligibility; and no applicant would be issued a Certificate of Eligibility for Admission or be admitted as a first-year medical student without the required NMAT qualification beginning school year 1986–87.

Administrative Implementation

Pursuant to MECS Order No. 52, the CEM administered NMAT examinations for admission to medical colleges during school year 1986–1987 and again in December 1986 and April 1987 for admission to school year 1987–1988. Petitioners either did not take or did not successfully hurdle the NMAT and sought judicial relief to enjoin further administration and enforcement of the NMAT requirement.

Legal Issues Presented

Primary legal issues: (1) Whether a preliminary injunction could properly be issued to enjoin enforcement of Section 5(a) and (f) of the Medical Act and MECS Order No. 52, s. 1985 pending the resolution of their constitutionality under the 1987 Constitution; (2) whether the statutory delegation to the Board violated the non-delegation doctrine; (3) whether the NMAT requirement is unfair, unreasonable, inequitable or a denial of due process; and (4) whether annual variation in cutoff scores violates equal protection.

Standard for Preliminary Injunction and Presumption of Constitutionality

The Court emphasized that issuance of a preliminary injunction to suspend enforcement of a statute or administrative order requires a petitioner to make a sufficiently strong prima facie showing of unconstitutionality to overcome the presumption that statutes and administrative orders are constitutional. Burden of proof rests on petitioners, and courts will not substitute their judgment for the political branches on matters of policy unless constitutional power is lacking.

Constitutional Claims under the 1987 Constitution

Petitioners invoked several provisions of the 1987 Constitution: Article II, Secs. 11, 13 and 17 (state policies valuing human dignity, youth welfare, and prioritizing education, science and technology); Article XIV, Sec. 1 (State shall protect and promote the right to quality education and take steps to make such education accessible to all); and Article XIV, Sec. 5(3) (every citizen’s right to select a profession, subject to fair, reasonable and equitable admission and academic requirements). The Court found petitioners failed to demonstrate how the statute and order conflicted with these State policies, and observed that Article XIV’s accessibility mandate must be read in relation to the express qualification in Sec. 5(3) that admission be subject to fair, reasonable and equitable requirements.

Non-Delegation Doctrine Analysis

Petitioners contended that Sections 5(a) and 5(f) of the Medical Act offended the non-delegation principle by failing to provide standards for the Board’s exercise of delegated authority. The Court applied established doctrine allowing subordinate rulemaking in complex technical fields and held that the Medical Act, read as a whole, supplies sufficient standards—specifically the Act’s objectives of “standardization and regulation of medical education” together with the detailed provisions on admission requirements—thereby rendering the delegation to the Board constitutional.

Due Process and Reasonableness of the NMAT Requirement

Petitioners argued the NMAT is unfair, unreasonable and inequitable, amounting to a denial of due process. The Court rejected this challenge as primarily a question of policy and wisdom, not of constitutional power. It held that the requirement is a valid exercise of the State’s police power directed to protecting public health and safety by regulating who may enter the medical profession. The Court found a reasonable relationship between requiri

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