Case Digest: George C. Cordero vs. Board of Nursing (GR No.
188646, September 21, 2016)
This case stemmed from the controversial June 2006 Philippine Regulatory Commission (PRC) nursing licensure exams,
which involved the leakage of actual examination questions. This incident damaged the credibility of professional
examinations in the country and tarnished the reputation of the Philippine nursing profession. One of the review centers
involved in the controversy was In-Ress Review Center, headed by George C. Cordero.
Events Before Filing the Case:
June 2006: The controversial nursing licensure exams take place, with allegations of question leakage.
June 8-9, 2006: In-Ress Review Center, headed by Cordero, holds a final coaching review session at a cinema in
SM Manila. During this session, topics were discussed through a PowerPoint presentation, which included
hypothetical scenarios and answers.
June 11-12, 2006: The nursing licensure exams are conducted.
Post-Exam: Allegations surface that the questions discussed during the In-Ress review session were identical to
actual questions on the exam.
October 12, 2006: The National Bureau of Investigation (NBI) releases a report on the investigation into the
question leakage, implicating In-Ress Review Center.
November 8, 2006: The Board of Nursing (Board) issues a summons to Cordero, requiring him to file a counter-
affidavit/verified answer to the formal charge against him.
Events After Filing the Case:
November 16, 2006: Cordero receives the summons and formal charge, accusing him of violating Section 15(a)
of Republic Act (RA) No. 8981 and Section 23(a), (b), and (f) of Article IV of RA No. 9173. The formal charge
alleges that Cordero made known or caused to be made known the licensure examination questions to his
reviewees prior to the exam.
Cordero's Defense: Cordero argues that the formal charge is not supported by evidence and violates his right to
due process. He claims that the Board did not follow proper procedures in filing the complaint and that the leak
originated from the PRC itself. He also states that his participation in the review session was limited to
welcoming reviewees and giving a pep talk.
March 13, 2008: Cordero raises the issue of jurisdiction and competence of the Board to hear his case before
the pre-trial conference.
Subsequent Filing: Cordero files a manifestation and motion emphasizing the lack of a proper complaint filed
according to PRC rules. He argues that the Board cannot be both complainant and judge in the case.
May 16, 2008: The Board denies Cordero's motion for lack of merit and sets the pre-trial conference.
September 21, 2016: The Supreme Court rules in favor of the Board of Nursing, finding that Cordero violated the
Code of Professional Responsibility and the Rules of Court. The Court upholds the Board's decision to revoke
Cordero's Certificate of Registration as a nurse.
Key Takeaways:
This case highlights the importance of ethical conduct and accountability in the nursing profession.
The Supreme Court emphasized the need for a fair and impartial process in disciplinary proceedings against
professionals.
The case underscores the potential consequences of unethical behavior, even if it is not directly proven that the
individual was responsible for the leakage of examination questions.
The case demonstrates the role of professional regulatory bodies in upholding standards and protecting the
public interest.
It is impossible to definitively say whether George C. Cordero's review session contained actual examination questions
by accident. The Supreme Court ruled that he violated the Code of Professional Responsibility and the Rules of Court,
but the specific circumstances surrounding the leakage and Cordero's knowledge are not fully clear from the available
information.
Cordero's Defense: He claimed that his participation in the review session was limited to welcoming reviewees
and giving a pep talk, suggesting he was not directly involved in preparing the review materials.
The Board's Argument: The Board of Nursing argued that Cordero, as the head of the review center, should
have been aware of the content of the review materials and that his actions violated ethical standards.
Supreme Court's Ruling: The Supreme Court found Cordero guilty of violating the Code of Professional
Responsibility and the Rules of Court, but the ruling does not explicitly address whether the leakage was
intentional or accidental.
involved the following individuals and entities:
George C. Cordero: The petitioner in the case, he was the head of In-Ress Review Center, a review center
accused of leaking nursing licensure exam questions.
Board of Nursing: The respondent in the case, they are the professional regulatory body responsible for
overseeing the nursing profession in the Philippines.
Philippine Regulatory Commission (PRC): The PRC is the government agency responsible for conducting and
overseeing professional licensure examinations in the Philippines.
National Bureau of Investigation (NBI): The NBI conducted an investigation into the nursing licensure exam
question leakage and released a report implicating In-Ress Review Center.
Carmencita Abaquin: The then chairperson of the Board of Nursing who signed the summons and formal charge
against Cordero.
Anesia B. Dionisio and Virginia D. Madeja: Board members who prepared the test questions for the June 2006
nursing licensure exams.
Facts:
The case stemmed from the controversial June 2006 Philippine Regulatory Commission (PRC) nursing licensure
exams, where allegations of question leakage surfaced.
In-Ress Review Center, headed by George C. Cordero, was implicated in the controversy.
On June 8-9, 2006, In-Ress held a final review session at a cinema in SM Manila, discussing topics through a
PowerPoint presentation.
Allegations arose that the questions discussed during this session were identical to actual questions on the June
11-12, 2006 nursing licensure exams.
The National Bureau of Investigation (NBI) released a report implicating In-Ress.
On November 16, 2006, Cordero received a summons and formal charge from the Board of Nursing (Board)
accusing him of violating Section 15(a) of Republic Act (RA) No. 8981 and Section 23(a), (b), and (f) of Article IV of
RA No. 9173.
The formal charge alleged that Cordero made known or caused to be made known the licensure examination
questions to his reviewees prior to the exam.
Cordero argued that the formal charge was not supported by evidence and violated his right to due process.
Issue:
Whether the Board of Nursing had the jurisdiction and competence to hear Cordero's case.
Whether Cordero violated the Code of Professional Responsibility and the Rules of Court by making known or
causing to be made known the licensure examination questions to his reviewees prior to the exam.
Ruling:
The Supreme Court ruled in favor of the Board of Nursing, finding that Cordero violated the Code of Professional
Responsibility and the Rules of Court.
The Court upheld the Board's decision to revoke Cordero's Certificate of Registration as a nurse.
The Court found that the Board had the jurisdiction and competence to hear the case, rejecting Cordero's
arguments about lack of a proper complaint and procedural irregularities.
The Court emphasized the importance of ethical conduct and accountability in the nursing profession, stating
that the Board's actions were necessary to protect the public interest.
Events Before Filing the Case:
1. Villanueva obtained a ₱1,000,000.00 loan from CABM PCI. This was the primary action that led to the case1.
2. Villanueva was the Assistant Regional Director of the CDA for Region II. This was her official position at the
time of the loan1.
3. Villanueva was a member of CABM PCI. She claimed she obtained the loan as a member, but the prosecution
argued it was due to her position1.
Events After Filing the Case:
1. An information for violation of Section 7(d) of RA 6713 was filed before the First Municipal Circuit Trial Court
of Claveria-Sta. Praxedes, Claveria, Cagayan (MCTC). This marked the official start of the legal proceedings1.
2. The MCTC found Villanueva guilty beyond reasonable doubt of violating Section 7(d) of RA 6713 and
sentenced her to five years imprisonment and disqualification to hold office. This was the initial verdict1.
3. Villanueva appealed to the Regional Trial Court (RTC). She challenged the MCTC's decision1.
4. The RTC affirmed Villanueva's conviction. The RTC upheld the MCTC's findings1.
5. Villanueva appealed to the Sandiganbayan. She continued to challenge the verdict1.
6. The Sandiganbayan affirmed the rulings of the lower courts. The Sandiganbayan upheld the conviction1.
7. Villanueva moved for reconsideration, which was denied. She sought to overturn the Sandiganbayan's
decision, but it was rejected1.
8. Villanueva filed a petition for review on certiorari before the Supreme Court. This was her final appeal1.
9. The Supreme Court affirmed Villanueva's conviction but modified the penalty to a fine of ₱5,000.00. The
Supreme Court upheld the Sandiganbayan's decision but reduced the sentence1.
This timeline shows the lengthy legal process that Villanueva went through, culminating in the Supreme Court's final
decision.
