The Supreme Court held that the Court of Appeals (CA) erred in reversing the decision of the Board for Professional Teachers (Board) to revoke a teacher’s license. The teacher failed to exhaust administrative remedies by not appealing first to the Professional Regulation Commission (PRC) before seeking recourse with the CA. Additionally, the Court found the teacher misrepresented her qualifications to obtain the license, thus, upholding the license revocation. This case underscores the importance of adhering to administrative procedures and truthful representation in professional licensure.

When Ambition Bypasses Procedure: A Teacher’s License Under Scrutiny

This case revolves around Dayamon Didato Alo, a public school teacher, and the Professional Regulation Commission (PRC)’s decision to revoke her professional teacher’s license. The PRC, acting through the Board for Professional Teachers, accused Alo of using a falsified Board Resolution to obtain her license. Alo contested this, claiming she qualified for licensure under Republic Act No. (RA) 7836, which allows experienced teachers to obtain licenses without examination under certain conditions. However, the Board found her guilty of misrepresentation, leading to the revocation of her license. Alo then directly appealed to the Court of Appeals, which reversed the Board’s decision, prompting the PRC to elevate the case to the Supreme Court. The central legal questions involve the CA’s jurisdiction, Alo’s due process rights, and the validity of the license revocation.

The Supreme Court first addressed the issue of jurisdiction. The PRC argued that Alo should have first appealed the Board’s decision to the PRC itself before going to the CA, citing Section 9(c) of RA 8981. This section outlines the powers of the Board and the appeal process. The Court clarified that while the PRC has appellate jurisdiction over the Board’s decisions, this does not strip the CA of its own appellate jurisdiction as defined under Batas Pambansa Bilang 129 (BP 129), as amended by RA 7902, also known as the Judiciary Reorganization Act of 1980. BP 129 grants the CA exclusive appellate jurisdiction over final judgments and orders of quasi-judicial agencies, instrumentalities, boards, or commissions.

Specifically, Section 9(3) of BP 129 states the Court of Appeals has “Exclusive appellate jurisdiction over all final judgments, decisions, resolutions, orders or awards of Regional Trial Courts and quasi-judicial agencies, instrumentalities, boards or commissions”. Consistent with this, Rule 43 of the Rules of Court provides the mechanism for appealing decisions of quasi-judicial agencies to the CA. The Court noted that the Board, in this case, acted as a quasi-judicial body when it investigated the matter, held hearings, and rendered a decision affecting Alo’s rights.

Despite establishing the CA’s jurisdiction, the Supreme Court emphasized that Alo failed to exhaust all available administrative remedies. The doctrine of **exhaustion of administrative remedies** requires that parties first pursue all available avenues within the administrative system before resorting to judicial intervention. This allows administrative agencies to correct their own errors and provides litigants with quicker and more affordable relief. The rationale behind this doctrine is to allow administrative agencies to use their expertise to resolve specialized matters before judicial intervention is sought. This principle was further underscored in Republic of the Philippines v. Lacap, where the Court highlighted the need to give administrative agencies the opportunity to resolve issues within their competence.

The Court found that Alo’s direct appeal to the CA was a blatant disregard of procedural rules and denied the PRC the opportunity to review the Board’s decision. Absent any recognized exceptions to the doctrine, such as estoppel, patent illegality, or unreasonable delay, the CA should have dismissed the petition for lack of cause of action. Thus, the Supreme Court determined that the CA erred in proceeding with the case.

Turning to the merits of the case, the Supreme Court addressed Alo’s qualifications for licensure under Section 26(C) of RA 7836. This section allows teachers with certain qualifications to obtain licenses without examination. However, the Board issued BPT Resolution 600-1997, clarifying that applicants under Section 26(C) must be incumbent teachers as of December 16, 1994, with at least five years of experience. Alo graduated from college and began teaching in 1995, making her ineligible under this provision.

Furthermore, Section 26 of RA 7836 originally allowed qualified teachers to register within two years of the Board’s organization, later extended to September 19, 2000, by BPT Resolution 600-1997. Alo only applied in September 2007, well beyond the deadline. As explained in St. Mary’s Academy v. Palacio, teachers failing to register by the deadline forfeited their privilege to practice without examination. The Court determined that Alo missed the registration deadline and could only qualify by passing the licensure examination, which she did not do. This underscores the importance of complying with statutory deadlines and regulatory requirements.

The Court rejected Alo’s claim that her right to due process was violated. While the formal charge focused on the alleged use of a falsified Board Resolution, Alo herself raised the issue of her qualifications under Section 26 of RA 7836. Therefore, the Board’s consideration of this issue did not violate her due process rights. The essence of **administrative due process** is simply the opportunity to be heard and present one’s case, as established in Ang Tibay v. Court of Industrial Relations. Alo was given ample opportunity to present evidence and arguments, satisfying the requirements of due process.

Finally, the Supreme Court addressed the CA’s reversal of the Board’s decision. The charge against Alo was for “use of fraud or deceit in obtaining a Certificate of Registration and Professional License, unprofessional conduct and/or dishonorable conduct”. This was allegedly committed by using a falsified Board Resolution No. 671, dated September 28, 2000, when she registered as a professional teacher on September 14, 2007.

While there was no direct evidence that Alo submitted a falsified copy of Board Resolution No. 671, she wrote “671 s’2000 E/C” on the Registry Book for Teachers, indicating that her name was included in the board resolution. However, the original Board Resolution No. 671 did not contain her name. This act constituted a misrepresentation of her qualifications, justifying the Board’s decision to revoke her license. The Court emphasized that substantial evidence supported the Board’s finding of guilt. Regardless of whether she relied on a fake document or simply misrepresented her qualifications, such actions constituted unprofessional or dishonorable conduct.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals (CA) erred in reversing the decision of the Board for Professional Teachers (Board) to revoke a teacher’s license, and whether the teacher had exhausted all administrative remedies.
Why did the Supreme Court reverse the CA’s decision?	The Supreme Court reversed the CA’s decision because the teacher failed to exhaust administrative remedies by not appealing to the Professional Regulation Commission (PRC) first, and because she misrepresented her qualifications to obtain the license.
What is the doctrine of exhaustion of administrative remedies?	The doctrine of exhaustion of administrative remedies requires that parties first pursue all available avenues within the administrative system before seeking judicial intervention, allowing administrative agencies to correct their own errors.
What is administrative due process?	Administrative due process is the right to be heard and present one’s case in an administrative proceeding, providing a fair opportunity to explain one’s side, which does not fully equate to due process in its strict judicial sense.
What was the basis for the Board’s decision to revoke the teacher’s license?	The Board revoked the teacher’s license because she misrepresented her qualifications by falsely claiming her name was included in Board Resolution No. 671 when she applied for registration.
Under what law did the teacher claim she was qualified for licensure?	The teacher claimed she was qualified for licensure under Section 26(C) of Republic Act No. 7836, which allows experienced teachers to obtain licenses without examination under certain conditions.
Why was the teacher deemed ineligible under Section 26(C) of RA 7836?	The teacher was deemed ineligible because she did not meet the requirement of being an incumbent teacher as of December 16, 1994, with at least five years of experience, as clarified by BPT Resolution 600-1997.
What was the significance of BPT Resolution 600-1997?	BPT Resolution 600-1997 clarified the requirements for licensure under Section 26(C) of RA 7836, specifying that applicants must be incumbent teachers as of December 16, 1994, and extended the registration deadline to September 19, 2000.

In conclusion, the Supreme Court’s decision underscores the necessity of exhausting administrative remedies before seeking judicial recourse and highlights the importance of truthful representation when applying for professional licenses. This ruling reinforces the authority of administrative bodies to regulate professions and ensures that individuals comply with established procedures and requirements.

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 vs. DAYAMON DIDATO ALO, G.R. No. 214435, February 14, 2022