Board of Medical Education vs. Alfonso

Courts may not substitute their judgment for that of the Secretary of Education on whether an educational institution meets prescribed standards; judicial review is limited to determining whether the Secretary acted within the scope of powers granted by law and the Constitution, or gravely abused such powers. A single ocular inspection by a trial judge does not warrant overturning the findings of multiple teams of qualified inspectors, and the three-year period before closure under MECS Order No. 5 applies only where deficiencies are remediable, not where they are so serious as to warrant immediate closure.

The Board of Medical Education (BME) is the government agency tasked with supervising and regulating the country's medical colleges, with the Secretary of the Department of Education, Culture and Sports (DECS) serving as its Chairperson. The Philippine Muslim-Christian College of Medicine Foundation, Inc. (the College) is a private educational institution founded in 1981, originally intended for Zamboanga City but established in Antipolo, Rizal, due to the unstable peace and order situation in Mindanao. It later adopted Antipolo as its permanent site and changed its name to the Rizal College of Medicine. The DECS, through MECS Order No. 5 (Series of 1986), promulgated the Essentials and Requirements for Medical Schools, setting minimum standards for medical education.

The Philippine Muslim-Christian College of Medicine Foundation, Inc. was founded in 1981 for the avowed purpose of producing physicians who would "emancipate Muslim citizens from age-old attitudes on health." Originally proposed for Zamboanga City, the College was established in Antipolo, Rizal, owing to the unstable peace and order situation in Mindanao, and was granted a temporary permit to operate there. It subsequently adopted Antipolo as its permanent site and changed its name to the Rizal College of Medicine.

In 1985, the DECS and the BME authorized the Commission on Medical Education to conduct a study of all medical schools in the Philippines. The resulting report showed that the College fell very much short of the minimum standards set for medical schools. The team of inspectors — Doctors Florentino Herrera, Jr., Elena Ines Cuyegkeng, Horacio Estrada, Jose V. Silao, Jr., and Andres L. Reyes — recommended closure upon findings that the College was not fulfilling its creation purpose due to its inappropriate location and absence of Muslim culture-related subjects; that its lack of university affiliation hindered students from obtaining a balanced education; that it did not have its own base hospital for clinical training as required by DECS; and that more than 60% of its faculty did not teach full-time, resulting in shortened and irregular class hours, subject overloading, and poor quality teaching. The College disputed these findings as biased and discriminatory.

At the College's request, the BME sent another team in May 1987 for a re-evaluation, which confirmed the previous findings and recommended a phase-out. A third team verified the first two reports on June 23, 1987. A fourth evaluation followed on March 4 and 5, 1988, conducted by Doctors Nilo Rosas, Macario Tan, and Elena Ines Cuyegkeng, which adjudged the College "inadequate" in all aspects — college, curriculum, facilities, teaching hospital, and studentry — and recommended denial of government recognition. The BME then recommended closure to the DECS, effective the end of school year 1988–1989. A fifth and final inspection was conducted on June 18, 1988 by Doctors Cuyegkeng, Alberto Romualdez, Artemio Ordinario, Joven Cuanang, and Nilo L. Rosas, who found that while there had been a major effort to improve the physical plant, serious deficiencies remained in clinical facilities, library operations, faculty adequacy, student profile, and academic medicine development. The recommendation was again to close the College, with provisions for dispersal of students to other medical schools.

Secretary Quisumbing, by letter of June 23, 1988, informed the Chairman of the College's Board of Trustees, Mr. Victor Sumulong, of the BME's decision to close the College. Sumulong proposed instead a gradual phase-out starting school year 1989–1990 to avoid dislocating students and staff and to minimize financial loss. The Board subsequently allowed the College to continue operations only until May 1989, declaring the decision "final and unappealable," while assuring assistance in relocating students and rehabilitating the institution for health-related and paramedical courses. The College appealed to the Office of the President, imputing grave abuse of discretion to the Secretary. On February 16, 1989, Executive Secretary Catalino Macaraig, Jr. affirmed the decision, finding "no reason to disturb" it.

On March 2, 1989, the College filed Civil Case No. 1385 before the RTC of Antipolo, Rizal, presided by Judge Daniel P. Alfonso, questioning the closure decision as illegal, oppressive, arbitrary, and discriminatory, and applying for a writ of preliminary injunction. Judge Alfonso issued the writ on May 10, 1989, ruling that the June 18, 1988 inspection — which he treated as the principal basis of the closure order — was conducted in an "arbitrary and haphazard manner" by inspectors who had prejudged the school. He held that no evidence supported the findings in the report and declared that his own ocular inspection disclosed that the deficiencies were non-existent, the laboratory and library areas being "big enough" and the operations of the proposed base hospital going on smoothly. The College promptly advertised in major newspaper dailies for enrollees in all levels of the medical college and in its pre-board review classes.

• Grave Abuse of Discretion by the Respondent Judge: Petitioners argued that the respondent judge gravely abused his discretion in issuing the preliminary injunction, thereby thwarting official action correctly taken to close a medical school that had repeatedly failed to meet minimum standards across five separate evaluations.
• Lack of Judicial Competence to Substitute Judgment: Petitioners maintained that no court has the power or competence to substitute its opinion for that of the Secretary of Education on whether an educational institution meets prescribed norms and standards, the evaluation of medical school fitness being a matter requiring specialized expertise.
• No Useful Purpose in Remand: Petitioners contended that remanding the case to the trial court would serve no useful purpose, as the only issue — whether the Secretary acted within her powers or gravely abused them — had already been passed upon by the Supreme Court.

• No Factual Basis for Closure: Respondent College argued that the closure order was issued without factual basis and in violation of its right to due process of law.
• Violation of MECS Order No. 5: Respondent College maintained that the closure violated MECS Order No. 5 (Series of 1986), which provides that the penalty of closure cannot be imposed earlier than three years from the last evaluation, which in this instance was conducted on June 18, 1988.
• Arbitrary and Haphazard Inspection: Respondent College claimed that the June 18, 1988 inspection was conducted in an arbitrary and haphazard manner by a team of inspectors who had already prejudged the school, and that the deficiencies mentioned in the report were non-existent as shown by the judge's own ocular inspection.

• Judicial Review of Administrative Action: Whether the respondent judge gravely abused his discretion in issuing a preliminary injunction that restrained the enforcement of the DECS Secretary's closure order against the College.
• Due Process: Whether the College was denied due process in the proceedings leading to the closure order.
• Statutory Compliance: Whether the closure order violated MECS Order No. 5 (Series of 1986), which provides that withdrawal of government authority to operate may not be imposed earlier than three years from the last evaluation.

• Judicial Review of Administrative Action: Yes. The respondent judge gravely abused his discretion by substituting his judgment — based on a single ocular inspection — for the findings of five teams of qualified inspectors, thereby thwarting official action correctly taken under the Secretary's statutory authority.
• Due Process: No. The College was not denied due process, having been given every opportunity to improve itself, to seek re-evaluation through multiple inspection teams, and to appeal all the way to the Office of the President.
• Statutory Compliance: No. The three-year waiting period under MECS Order No. 5, paragraph (c) applies only where deficiencies are remediable; it does not bar immediate closure where deficiencies are so serious as to be irremediable, as was the case here.

• Judicial Review of Administrative Action: Courts of justice should not generally interfere with purely administrative and discretionary functions, and have no supervisory power over proceedings and actions of administrative departments involving the exercise of judgment and findings of fact. By reason of their special knowledge and expertise over matters falling within their jurisdiction, administrative agencies are in a better position to pass judgment on such matters, and their findings of fact are generally accorded respect, if not finality, by the courts. The only authority reposed in the courts is the determination of whether the Secretary acted within the scope of powers granted by law and the Constitution, or gravely abused such powers. Here, the record showed that from 1985, no less than five surveys were conducted of the College, all confirming serious deficiencies and recommending closure. The members of the evaluating teams came from different sectors in the fields of education and medicine, and their judgment was certainly better than that of the respondent judge, whose sole visit to the school could hardly have given him more than a brief look at the physical plant and facilities. The judge gravely abused his discretion in substituting his judgment for theirs.

• Due Process: The record clearly showed that the College was given every opportunity to improve itself to come up to requirements, but remained sub-standard after inspections by multiple evaluating teams. The College had, in fact, admitted its failure to meet desired standards when it proposed a gradual phase-out in its letter dated June 27, 1988 to Secretary Quisumbing. It was precisely because of its complaints of bias and prejudice that the BME dispatched new teams to re-evaluate its performance. It had even gone to the Office of the President to seek reversal of the closure order. There was thus no reason to complain of a lack of opportunity to be heard, to explain its side, or to seek reconsideration.

• Statutory Compliance: The provision in MECS Order No. 5, paragraph (c) — contemplating withdrawal of authority to operate "for failure to fully comply with the prescribed requirements after three (3) years from the last evaluation conducted on the school" — addresses a situation distinct from that obtaining in the case. The provision should be read as giving the Secretary the discretion, depending on the seriousness of discovered deficiencies, to afford an institution time not exceeding three years to correct deficiencies before applying the sanction of closure. It does not unexceptionally prescribe a three-year waiting period before authority to operate may be withdrawn. In this case, the deficiencies were so serious as to be irremediable; from the outset, the proposal had been forthwith closure, not an opportunity to comply with certain requirements. The subsequent surveys over a period of more than three years served only to confirm the validity of the initial proposal for closure. Even assuming the provision applied, there had been substantial compliance therewith.

• Doctrine of Non-Interference with Administrative Discretion — Courts of justice should not generally interfere with purely administrative and discretionary functions; courts have no supervisory power over proceedings and actions of administrative departments involving the exercise of judgment and findings of fact, because by reason of their special knowledge and expertise over matters falling under their jurisdiction, administrative agencies are in a better position to pass judgment on such matters, and their findings of fact are generally accorded respect, if not finality, by the courts. The Court applied this doctrine to hold that the respondent judge could not substitute his judgment — based on a single ocular inspection — for the findings of five teams of qualified medical education inspectors.

• Scope of Judicial Review over Administrative Action — The only authority reposed in the courts regarding decisions of the Secretary of Education is the determination of whether the Secretary acted within the scope of powers granted by law and the Constitution. As long as it appears that the Secretary has done so, any decision rendered should not be subject to review and reversal by any court. Only where powers are exercised whimsically, capriciously, oppressively, despotically, or arbitrarily — constituting grave abuse of discretion — may the Court rectify such action through certiorari, prohibition, or mandamus. Even then, absent compelling reason, the Court should leave to the Secretary the ultimate determination of whether an educational institution satisfies the standards for its legitimate operation.

• Remediable vs. Irremediable Deficiencies in School Closure — The three-year waiting period under MECS Order No. 5, paragraph (c) before withdrawal of government authority to operate applies only where deficiencies are remediable and the school is given an opportunity to comply. Where deficiencies are so serious as to be irremediable and warrant immediate closure from the outset, the three-year period does not bar the sanction. The provision should be construed as granting the Secretary discretion, depending on the seriousness of discovered deficiencies, to afford an institution time not exceeding three years to correct deficiencies before closure.

• "It is not the function of this Court or any other Court to review the decisions and orders of the Secretary on the issue of whether or not an educational institution meets the norms and standards required for permission to operate and to continue operating as such. On this question, no Court has the power or prerogative to substitute its opinion for that of the Secretary." — This passage articulates the core ratio decidendi: the limited scope of judicial review over administrative decisions involving specialized expertise in educational standards.

• "It is well-settled doctrine that courts of justice should not generally interfere with purely administrative and discretionary functions; that courts have no supervisory power over the proceedings and actions of the administrative departments of the government involving the exercise of judgment and findings of facts, because by reason of their special knowledge and expertise over matters falling under their jurisdiction, the latter are in a better position to pass judgment on such matters and their findings of facts in that regard are generally accorded respect, if not finality, by the courts." — This is the canonical formulation of the doctrine of non-interference with administrative discretion as applied in this case, frequently cited in subsequent jurisprudence on judicial review of administrative action.

• "Said paragraph c should not be construed to prohibit absolutely the withdrawal or cancellation of government authority to operate until after three (3) years from the last evaluation conducted on the school; or, stated otherwise, it does not unexceptionally prescribe a three-year waiting period before authority to operate may be withdrawn. Rather, it should be read as giving the Secretary of Education the discretion, depending on the seriousness of the discovered deficiencies, to afford an educational institution which has failed to comply with some requirement or other, time not exceeding three (3) years to correct the deficiencies before applying the sanction of withdrawal or cancellation of the government authority to operate." — This passage defines the Court's interpretation of MECS Order No. 5, paragraph (c), distinguishing remediable from irremediable deficiencies in the context of school closure sanctions.

• Ateneo de Manila vs. Court of Appeals, 145 SCRA 106 — Cited as supporting authority for the doctrine that courts should not interfere with purely administrative and discretionary functions, and that findings of fact by administrative agencies are accorded respect, if not finality.
• Lianga Bay Logging Co., Inc. vs. Lopez Enage, 152 SCRA 80 — Cited alongside Ateneo de Manila for the same doctrine of non-interference with administrative discretion and deference to agency findings of fact.
• Alcuaz vs. PSBA, G.R. No. 76353, May 2, 1988 — Cited as additional authority for the principle that courts have no supervisory power over administrative proceedings involving the exercise of judgment and findings of fact within the agency's special expertise.

• MECS Order No. 5, Series of 1986 (Essentials and Requirements for Medical Schools) — This order prescribed the minimum standards for medical schools in the Philippines. Paragraph (c) thereof provided for withdrawal or cancellation of a school's government authority to operate for failure to fully comply with prescribed requirements after three years from the last evaluation. The Court construed this provision as discretionary rather than mandatory, applying only to remediable deficiencies and not to those so serious as to warrant immediate closure.
• 1987 Constitution (implied) — The decision references the constitutional grant of power to the Secretary of Education to regulate educational institutions, and the corresponding limitation on judicial power to review such regulatory action absent grave abuse of discretion.

Chief Justice Fernan, and Justices Gutierrez, Jr., Cruz, Paras, Feliciano, Gancayco, Padilla, Bidin, Cortes, Griño-Aquino, Medialdea, and Regalado concurred.