The Supreme Court ruled that the Professional Regulation Commission (PRC) can withhold administering the physician’s oath and issuing certificates of registration if there are serious doubts about the integrity of the licensure examination results. This decision clarifies that while successful examinees generally have a right to be registered, this right is not absolute and can be superseded by concerns about the validity of the examination process. The ruling highlights the PRC’s duty to ensure the competence and ethical standards of medical professionals, even if it means delaying or denying the registration of those who appear to have passed the exam.

Doubt and Discretion: When Licensure Examination Results Raise Red Flags

This case arose from the February 1993 Physician Licensure Examination where the Board of Medicine noticed exceptionally high scores from graduates of Fatima College of Medicine, particularly in Biochemistry and Obstetrics and Gynecology. Many examinees achieved perfect or near-perfect scores, an unprecedented phenomenon. The Board withheld the registration of these examinees, prompting them to file a special civil action for mandamus, seeking to compel the PRC to administer their oath and register them as licensed physicians. The legal question centered on whether the PRC had a ministerial duty to register the examinees, or whether it could exercise discretion due to the concerns about the examination’s integrity.

The Court emphasized that while Section 20 of the Medical Act of 1959 uses the word “shall” regarding the issuance of certificates of registration, implying a mandatory duty, this provision must be read in conjunction with the other sections of the Act. Specifically, Section 22 grants the Board the power to conduct administrative investigations and “disapprove applications for examination or registration” to maintain the ethical and professional standards of the medical profession. This power allows the Board to address concerns about an examinee’s qualifications or the integrity of the examination process.

The Supreme Court acknowledged the right of every citizen to select a profession but reiterated that this right is subject to regulation under the State’s police power. Licensing requirements, such as passing a board examination, are designed to protect the public from the potential harm caused by incompetent practitioners. However, such regulations must be fair, reasonable, and equitable, and cannot be used to arbitrarily deny individuals the right to practice their chosen profession.

In this case, the Court found that the Board had reasonable grounds to doubt whether the respondents had “satisfactorily passed” the licensure examinations, given the unusually high scores and the NBI investigation suggesting early access to test questions. The Court quoted Section 8 of Rep. Act No. 2382, emphasizing that no person shall engage in the practice of medicine unless they have “satisfactorily passed the corresponding Board Examination”. Furthermore, the Board had filed administrative charges against the respondents for “immorality, dishonesty, fraud, and deceit in the Obstetrics-Gynecology and Biochemistry examinations,” indicating that their qualifications were under serious question.

The Court further explained the nature and limitations of the writ of mandamus. The writ of mandamus is a legal remedy used to compel a government agency to perform a duty that is considered mandatory. However, it cannot be used to compel performance of an act which is not duly authorized. For mandamus to prosper, there must be a showing that the officer, board, or official concerned, has a clear legal duty, not involving discretion.

The Court cited legal precedents to support the importance of protecting the public from the risks associated with medical malpractice and noted that a license to practice medicine is a privilege granted by the government, not an absolute right. The government may exercise its power to grant or refuse such privilege in accordance with certain conditions.

Building on this principle, the Court dismissed the contention that the administrative remedies had not been exhausted. They aver that none of these circumstances are present in their case, thus mandamus will not lie when administrative remedies are still available. On this issue, no reversible error may, thus, be laid at the door of the appellate court in CA-G.R. SP No. 37283, when it refused to dismiss Civil Case No. 93-66530. Section 26^[45] of the Medical Act of 1959 provides for the administrative and judicial remedies.

In conclusion, the Supreme Court reversed the appellate court’s decision, holding that the PRC did not have a ministerial duty to administer the oath and register the respondents as physicians under the specific circumstances of the case.

FAQs

What was the key issue in this case?	The central issue was whether the PRC had a ministerial duty to administer the physician’s oath and issue certificates of registration to examinees who passed the licensure exam but whose results were under suspicion due to unusually high scores.
What is a writ of mandamus?	A writ of mandamus is a court order compelling a government agency or official to perform a mandatory duty. It is used when the agency has unlawfully neglected a duty that the law specifically requires them to perform.
Under what conditions can the PRC withhold registration?	The PRC can withhold registration if there are doubts about the integrity of the examination process or the qualifications of the examinees, even if they technically passed the exam. This is to maintain the ethical and professional standards of the medical profession.
What is the legal basis for the PRC’s power to regulate medical licensing?	The PRC’s power is derived from the Medical Act of 1959 and the State’s police power, which allows the government to regulate professions to protect public health, safety, and welfare. This includes setting standards for medical education, examination, and practice.
Is the right to choose a profession absolute?	No, the right to choose a profession is not absolute. It is subject to reasonable regulations and conditions imposed by the State to ensure competence and protect the public from harm.
What role did the unusually high scores play in the court’s decision?	The unusually high scores were a critical factor, raising serious doubts about whether the respondents had legitimately passed the examinations. This justified the Board’s decision to withhold registration pending further investigation.
Was this about the fitness to practice or validity of the test?	The case involved the validity of the test. Until their mental and moral fitness could be evaluated, the Board had the right to wait to do a Hipocratic Oath and issue certificates of the respondents.
How are the rules for appeal addressed in this case?	Section 26 of the Medical Act of 1959, states that the rules of appeal can be used to question Resolution No. 26 of the Board of Medicine with a special civil action of certiorari

This decision serves as a reminder that professional licensing is not merely a procedural formality, but a crucial mechanism for ensuring public safety and maintaining the integrity of regulated professions. The PRC has a duty to investigate any irregularities in the licensure process and to take appropriate action to protect the public interest.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: PROFESSIONAL REGULATION COMMISSION (PRC) vs. ARLENE V. DE GUZMAN, G.R. No. 144681, June 21, 2004