Title
Tablarin vs. Gutierrez
Case Decision Date
G.R. No. 78164 Jul 31, 1987
Petitioners challenged the NMAT requirement for medical school
admission, claiming it violated constitutional rights. The Supreme Court
upheld its constitutionality, ruling it a valid exercise of state police power to
ensure quality medical education and public health.
Jur.ph - Case Digest (G.R. No. 78164)
Reasoning Model - Advanced
Facts:
Petitioners’ Application for Admission to Medical Schools
Petitioners, representing several aspiring medical students, sought
admission into medical colleges for the school year 1987–1988 and future
years.
They had either not taken or not successfully passed the National Medical
Admission Test (NMAT), a requirement established by the Board of Medical
Education and administered by the Center for Educational Measurement
(CEM).
Filing of the Petition and Trial Court Proceedings
On March 5, 1987, the petitioners filed a Petition for Declaratory Judgment
and Prohibition in the Regional Trial Court of the National Capital Judicial
Region.
The petition sought to enjoin:
The Secretary of Education, Culture and Sports,
The Board of Medical Education, and
The Center for Educational Measurement
from enforcing Section 5 (a) and (f) of Republic Act No. 2382 (as amended) and
MECS Order No. 52, s. 1985, which mandated the NMAT requirement.
Statutory and Administrative Framework
Republic Act No. 2382 (the “Medical Act of 1959”), as amended by Republic
Acts Nos. 4224 and 5946, laid down:
Objectives for the standardization and regulation of medical education,
Examination and certification requirements for physicians,
The supervision and regulation of the practice of medicine in the
Philippines.
The Act established the Board of Medical Education comprising key
government and academic representatives, with defined functions
including:
Setting admission requirements for recognized colleges of medicine,
Prescribing standards for facilities, teaching personnel, the curriculum, and
more.
Section 7 of the Act prescribed additional admission requirements
concerning academic background and moral character.
Implementation of the NMAT Requirement
MECS Order No. 52, s. 1985, issued by the then Minister of Education,
established a uniform admission test (NMAT) as an additional requirement
for certification of eligibility for admission into medical schools.
The Order detailed:
The NMAT’s role as an aptitude test to upgrade the selection process and
improve the quality of medical education,
The determination of cutoff scores by the Board of Medical Education in
consultation with the Association of Philippine Medical Colleges,
That no applicant would be issued the Certificate of Eligibility for Admission
without meeting the NMAT qualification.
Procedural Posture and Constitutional Challenge
After the Regional Trial Court’s denial of the temporary relief, petitioners
filed a Special Civil Action for Certiorari before the Supreme Court.
Petitioners raised constitutional challenges, arguing that the statutory and
administrative measures:
Violated several provisions of the 1987 Constitution (including rights to
quality education, fair admission, and protection of human dignity),
Constituted an undue delegation of legislative power,
Imposed an unfair and arbitrary requirement by setting a variable cutoff
score for each testing period.
Issue:
Whether the petitioners are entitled to a writ of preliminary injunction to
temporarily enjoin the enforcement of:
Section 5 (a) and (f) of Republic Act No. 2382 (as amended), and
MECS Order No. 52, s. 1985.
Whether the requirements imposed by the statute and administrative order,
particularly the NMAT, violate several specific constitutional provisions:
Articles II and XIV of the 1987 Constitution concerning human dignity,
youth development, quality education, and fair admission,
The equal protection clause, given the variability in the cutoff scores
applied annually.
Whether the delegation of legislative power inherent in the statutory
framework and the administrative imposition of the NMAT violates the non-
delegation doctrine.
Ruling:
Denial of Petition for Preliminary Injunction
The Supreme Court held that a writ of preliminary injunction is appropriate
only when there is a strong prima facie case of unconstitutionality that
overcomes the presumption of constitutionality.
Given the petitioners’ failure to persuasively demonstrate that the
challenged statutory and administrative provisions are in violation of the
Constitution, the application for preliminary injunction is denied.
Upheld Validity of the NMAT Requirement and Related Provisions
The Court found that both the NMAT requirement and the provisions of
Republic Act No. 2382 do not violate any constitutional guarantees.
It affirmed the trial court’s order denying the petition for a writ of
preliminary injunction, thereby upholding the continued enforcement of
the NMAT as scheduled.
Dismissal of the Petition for Certiorari
The petition for certiorari was dismissed.
Costs were ordered against the petitioners.
Ratio:
Presumption of Constitutionality
A statute or administrative order is presumed to be constitutional unless
strong evidence is presented to the contrary.
The petitioners failed to meet the heavy burden of proof required to
overcome this presumption.
Delegation of Legislative Power
The Court recognized that while legislative power is non-delegable in
principle, modern complexities necessitate delegation through subordinate
legislation.
By referring to established precedents, the Court held that the standards set
in the Medical Act of 1959 and its corresponding sections provided a
sufficient basis for the delegation of power.
The broad and flexible standards defined in the legislation adequately
address the technical and complex nature of medical education regulation.
Exercise of Police Power
The regulation of the practice of medicine, including the setting of
admission requirements, is a valid exercise of the state’s police power.
The NMAT is reasonably related to the state’s interest in improving the
quality of medical education and protecting the health and safety of the
public by ensuring that only qualified candidates are admitted to medical
schools.
Variability of the NMAT Cutoff Scores
The ability to adjust cutoff scores annually is not arbitrary or capricious.
The flexibility in score determinations is justified by changing
circumstances such as applicant performance, available seats, and test
difficulty.
The Court noted that rigid adherence to an unchanging cutoff score could
hinder the intended quality control of the admission process.
Constitutional Framework and Equal Protection
The petitioners’ invocation of various constitutional provisions was found
lacking in demonstrating a substantive clash with the statutory and
administrative measures.
The parameters for admission set by law and by MECS Order No. 52 were
deemed consistent with the objective of ensuring quality and equitable
access based on established, fair, and reasonable criteria.
Doctrine:
Principle of Presumption of Constitutionality
Legislative and administrative actions are assumed to be constitutional
until a persuasive case is made to the contrary.
This principle places a heavy burden on petitioners to prove otherwise,
particularly when challenged provisions are stated in general yet purposive
language.
Non-Delegation and Subordinate Legislation
The doctrine of non-delegation does not prohibit all delegation of legislative
power, especially in complex regulatory environments.
Statutory frameworks like the Medical Act of 1959 may validly delegate
authority to administrative bodies, provided the delegated power remains
within the ambit of the legislative purpose.
Courts are empowered to assess whether such delegations conform to the
standards and policies set out in the parent legislation.
Exercise of Police Power in Regulating Professional Standards
The regulation of professions, including the imposition of admission tests
like the NMAT, is recognized as a legitimate exercise of police power.
Such exercises aim to protect public health and safety by ensuring that only
qualified individuals are admitted to practice professions that have
significant social impact.
The rationale is supported by historical precedents and comparative
practices in other jurisdictions, underscoring its validity.
Equal Protection and Flexibility in Regulatory Standards
The doctrine of equal protection does not require rigid uniformity in
regulatory measures, as long as differences are justified by reasonable and
contextual factors.
The ability to adjust the NMAT cutoff score annually is given deference due
to the variable nature of candidate pools and educational circumstances.
Such regulatory flexibility is essential to maintaining high standards in
medical education, a goal consistent with safeguarding public welfare.
