Constitutional Law2 Professional Regulations Commission Vs de Guzman GR No 144681 June 2004 January 22, 2020 CASE DIGEST

8/13/2019 43571324 Digest PRC vs de Guzman
PRC vs. De Guzman, G. R. No. 144681, June 21, 2004

Constitutional Law: Police Power
Facts: The respondents are all graduates of the Fatima College of Medicine, Valenzuela City, Metro Manila. They
passed the Physician Licensure Examination conducted in February 1993 by the Board of Medicine (Board). Petitioner
Professional Regulation Commission (PRC) then released their names as successful examinees in the medical licensure
examination.
Shortly thereafter, the Board observed that the grades of the seventy-nine successful examinees from Fatima College in
the two most difficult subjects in the medical licensure exam, Biochemistry (Bio-Chem) and Obstetrics and Gynecology
(OB-Gyne), were unusually and exceptionally high. Eleven Fatima examinees scored 100% in Bio-Chem and ten got
100% in OB-Gyne, another eleven got 99% in Bio-Chem, and twenty-one scored 99% in OB-Gyne. The Board also
observed that many of those who passed from Fatima got marks of 95% or better in both subjects, and no one got a
mark lower than 90%. A comparison of the performances of the candidates from other schools was made. The Board
observed that strangely, the unusually high ratings were true only for Fatima College examinees. It was a record-
breaking phenomenon in the history of the Physician Licensure Examination.
For its part, the NBI found that “the questionable passing rate of Fatima examinees in the [1993] Physician Examination
leads to the conclusion that the Fatima examinees gained early access to the test questions.”
The Board issued Resolution No. 26, dated July 21, 1993, charging respondents with "immorality, dishonest conduct,
fraud, and deceit" in connection with the Bio-Chem and Ob-Gyne examinations. It recommended that the test results of
the Fatima examinees be nullified. Trial court’s judgment is rendered ordering the respondents to allow the petitioners
and intervenors to take the physician’s oath and to register them as physicians without prejudice to any administrative
disciplinary action which may be taken against any of the petitioners for such causes and in the manner provided by
law and consistent with the requirements of the Constitution as any other professionals.
Issue: Whether or not the act pursuant to R.A. 2382 (prescribes that a person who aspires to practice medicine in the
Philippines, must have “satisfactorily passed the corresponding Board Examination) known as The Medical Act of 1959 a
valid exercise of police power.
Held:
Yes. It is true that this Court has upheld the constitutional right of every citizen to select a profession or course of study
subject to a fair, reasonable, and equitable admission and academic requirements. But like all rights and freedoms
guaranteed by the Charter, their exercise may be so regulated pursuant to the police power of the State to safeguard
health, morals, peace, education, order, safety, and general welfare of the people. Thus, persons who desire to
engage in the learned professions requiring scientific or technical knowledge may be required to take an examination
as a prerequisite to engaging in their chosen careers. This regulation takes particular pertinence in the field of medicine,
to protect the public from the potentially deadly effects of incompetence and ignorance among those who would
practice medicine.
*satisfactorily- defined as “sufficient to meet a condition or obligation” or “capable of dispelling doubt or ignorance”
It must be stressed, nevertheless, that the power to regulate the exercise of a profession or pursuit of an occupation
cannot be exercised by the State or its agents in an arbitrary, despotic, or oppressive manner. A political body that
regulates the exercise of a particular privilege has the authority to both forbid and grant such privilege in accordance
with certain conditions. Such conditions may not, however, require giving up ones constitutional rights as a condition to
acquiring the license.
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8/13/2019 43571324 Digest PRC vs de Guzman

PRC vs. De Guzman, G. R. No. 144681, June 21, 2004

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