PRC VS Alo - Rem

PRC VS. ALO, SECOND DIVISION, FEB 14, 2022, G.R. No.
214435; HERNANDO
CIVIL PROCEDURE – NATURE OF APPEAL - APPEALS FROM THE CTA, CSC, AND QUASI-JUDICIAL
AGENCIES
DOCTRINE
There is no law granting the PRC exclusive appellate jurisdiction over cases decided by the Board, nor is
there any law excluding such cases from being taken cognizance by the CA through a petition for review
under Rule 43 of the Rules of Court, as will be discussed further below.
Rule 43 of the Rules of Court grants the CA exclusive appellate jurisdiction over all final judgments,
decisions, resolutions, orders or awards of RTCs and quasi-judicial agencies, instrumentalities, boards or
commissions.
It is clear from the above provisions that a Rule 43 petition to the CA includes all awards, judgments,
final orders or resolutions of or authorized by any quasi-judicial agency in the exercise of its quasi-judicial
functions.
SUMMARY
Alo was charged before the Board for Professional Teachers, which operates under the
Professional Regulation Commission, for using fraud or deceit in obtaining a certificate of registration
and professional license. The Board rendered a decision against Alo, who then files a motion for
reconsideration which the Board denied. Without elevating the case to the PRC, Alo directly filed a
petition for review with the CA under Rule 43 of the Rules of Court.
FACTS:
Dayamon Didato Alo (Alo) was formally charged with unprofessional conduct and/or dishonorable
conduct before the Board for Professional Teachers (Board), which operates under Professional
Regulation Commission (PRC), for using fraud or deceit in obtaining a certificate of registration and
professional license, by using a falsified Board Resolution No. 671.
Alo alleged in her counter-affidavit that she is a holder of a degree in Bachelor of Science in Elementary
Education and had been a public elementary school teacher in Kalanganan Elementary School from 1995
to 2006, and is currently a public school teacher in Tambo Cadayonan Elementary School. Alo, who was
not a passer of the board examination for professional teachers, allegedly went to the PRC Head Office in
Manila to apply for a Professional Teacher's License based on Section 26 (C) of Republic Act No. (RA)
7836. This law provides certain conditions which grants a certificate of registration and professional
license to qualified applicants without the need for examination. She filled out forms by the PRC, and
was subsequently issued a professional identification card a few days later. Further, she stressed that she
never submitted the alleged falsified Board Resolution No. 671.
The Board rendered a decision against Alo, who then files a motion for reconsideration which the Board
denied. Without elevating the case to the PRC, Alo directly filed a petition for review with the CA under
Rule 43 of the Rules of Court. CA issued a Minute Resolution requiring the Board and the PRC, which was
impleaded in the petition, to file their comment on Alo's petition for review. However, since the Board
and the PRC failed to file their comment within the reglementary period, the CA deemed that they
waived the filing of their comment and submitted the instant case for decision without comment.
Thus, CA rendered the assailed Decision, granting Alo's petition for review and reversing the ruling of the
Board. The Board and the PRC filed a motion for reconsideration, which was denied. PRC argues that the
CA has no jurisdiction to directly review the September 11, 2012 decision of the Board. To support this
contention, the PRC cites Section 9 (c) of RA 8981, which enumerates the powers of the Board, including
the power to make decisions, and the mode of appeal of an aggrieved party.
ISSUE:
Does the CA have jurisdiction to directly review the Board's decision, considering that the same belongs
to the PRC?
HELD:
Yes, the CA has jurisdiction to directly review the Board’s decision.
This Court has long held that jurisdiction over the subject matter is the power to hear and determine the
general class to which the proceedings in question belong; it is conferred by law and not by the consent
or acquiescence of any or all of the parties or by erroneous belief of the court that it exists.
PRC cited the provision of Sec. 9(c) of R.A8981, while showing that they may have appellate jurisdiction
over decisions or orders of the Board, this does not divest the CA of its own appellate jurisdiction. To put
it simply, there is no law granting the PRC exclusive appellate jurisdiction over cases decided by the
Board, nor is there any law excluding such cases from being taken cognizance by the CA through a
petition for review under Rule 43 of the Rules of Court, as will be discussed further below.
Rule 43 of the Rules of Court grants the CA exclusive appellate jurisdiction over all final judgments,
decisions, resolutions, orders or awards of RTCs and quasi-judicial agencies, instrumentalities, boards or
commissions. Rule 43 of the Rules of Court provides:
RULE 43. Appeals from the Court of Tax Appeals and Quasi-Judicial Agencies to the Court of Appeals
Section 1. Scope. — This Rule shall apply to appeals from judgments or final orders of the Court of Tax
Appeals and from awards, judgments, final orders or resolutions of or authorized by any quasi-judicial
agency in the exercise of its quasi-judicial functions. Among these agencies are the Civil Service
Commission, Central Board of Assessment Appeals, Securities and Exchange Commission, Office of the
President, Land Registration Authority, Social Security Commission, Civil Aeronautics Board, Bureau of
Patents, Trademarks and Technology Transfer, National Electrification Administration, Energy Regulatory
Board, National Telecommunications Commission, Department of Agrarian Reform under Republic Act
No. 6657, Government Service Insurance System, Employees Compensation Commission, Agricultural
Invention Board, Insurance Commission, Philippine Atomic Energy Commission, Board of Investments,
Construction Industry Arbitration Commission, and voluntary arbitrators authorized by law.
Section 2. Cases not covered. — This Rule shall not apply to judgments or final orders issued under the
Labor Code of the Philippines.
It is clear from the above provisions that a Rule 43 petition to the CA includes all awards, judgments,
final orders or resolutions of or authorized by any quasi-judicial agency in the exercise of its quasi-judicial
functions.
Given this, there is no question that the September 11, 2012 Decision of the Board is covered by the
jurisdiction of the CA and can be subject of a Rule 43 petition.

PRC VS Alo - Rem

Uploaded by

Copyright:

Available Formats

PRC VS Alo - Rem

Uploaded by

Document Information

Original Title

Copyright

Available Formats

Share this document

Share or Embed Document

Sharing Options

Did you find this document useful?

Is this content inappropriate?

Copyright:

Available Formats

PRC VS Alo - Rem

Uploaded by

Copyright:

Available Formats

PRC VS. ALO, SECOND DIVISION, FEB 14, 2022, G.R. No.

Yes, the CA has jurisdiction to directly review the Board’s decision.

You might also like