The State, in the exercise of its police power, can validly regulate admission to medical schools, including imposing a limit on the number of times an individual can take the National Medical Admission Test (NMAT), to ensure that only qualified individuals enter the medical profession and to protect public health and safety.

The case arose from the implementation of MECS Order No. 12, Series of 1972, specifically rule h) which states: "A student shall be allowed only three (3) chances to take the NMAT. After three (3) successive failures, a student shall not be allowed to take the NMAT for the fourth time." This rule was part of the government's effort to upgrade the quality of medical education and ensure that only competent individuals are admitted to medical schools, thereby safeguarding public health. The NMAT itself was established as a qualifying examination for admission to medical schools.

• Private respondent Roberto Rey C. San Diego, a graduate of the University of the East with a Bachelor of Science in Zoology, took the National Medical Admission Test (NMAT) three times and failed each time.
• When San Diego applied to take the NMAT for a fourth time, his application was rejected by the petitioners based on MECS Order No. 12, Series of 1972, specifically rule h), which limits a student to three chances to take the NMAT.
• San Diego filed a petition for mandamus in the Regional Trial Court (RTC) of Valenzuela, invoking his constitutional rights to academic freedom and quality education.
• By agreement of the parties, San Diego was allowed to take the NMAT scheduled on April 16, 1989, subject to the outcome of his petition; he also failed this test.
• San Diego later amended his petition to squarely challenge the constitutionality of the "three-flunk rule," adding grounds of due process and equal protection.
• The respondent judge, Teresita Dizon-Capulong, rendered a decision on July 4, 1989, declaring the challenged order invalid, holding that San Diego had been deprived of his right to pursue a medical education through an arbitrary exercise of police power.
• A check with the Department of Education revealed that San Diego had actually taken and flunked the NMAT four times and was applying for a fifth examination.

• The DECS rule limiting NMAT attempts to three is a valid exercise of police power intended to regulate admission to medical schools and ensure the competence of future medical practitioners, thereby protecting public health.
• The "three-flunk rule" is a reasonable means to achieve the legitimate state objective of upgrading the quality of medical education and preventing the admission of individuals who have repeatedly demonstrated a lack of aptitude for medical studies.
• The rule does not violate the equal protection clause as there is a substantial distinction between medical students and other students, given the direct impact of the medical profession on public health and safety.
• The rationale of Tablarin v. Gutierrez, which upheld the NMAT requirement, also applies to the "three-flunk rule" as both concern the academic preparation and aptitude of applicants to medical schools.

• The "three-flunk rule" under MECS Order No. 12, Series of 1972, is unconstitutional as it violates his rights to academic freedom and quality education.
• The rule constitutes an arbitrary exercise of police power, depriving him of his right to pursue a medical education without due process of law.
• The rule violates the equal protection clause, as it unfairly discriminates against him.
• The case of Tablarin v. Gutierrez is not applicable because it only upheld the NMAT requirement itself, not the "three-flunk rule."

• Whether MECS Order No. 12, Series of 1972 (the "three-flunk rule" for NMAT) is a valid exercise of the State's police power.
• Whether the "three-flunk rule" violates the private respondent's constitutional rights to academic freedom, quality education, due process, and equal protection.

• The Supreme Court granted the petition, reversed the decision of the respondent court, and upheld the constitutionality of the DECS "three-flunk rule."
• The Court ruled that the "three-flunk rule" is a valid exercise of police power, as it serves the legitimate state interest of ensuring that only competent individuals are admitted to medical schools to protect public health.
• The method employed (limiting NMAT attempts) is reasonably necessary for the purpose and is not arbitrary or oppressive, as it aims to filter out those not qualified for the medical profession.
• The right to quality education is not absolute and is subject to fair, reasonable, and equitable admission and academic requirements; the State has the responsibility to ensure that human resources are not dissipated or misapplied.
• The rule does not violate the equal protection clause because a substantial distinction exists between medical students (and the medical profession) and others, justifying more stringent regulation due to the direct impact on public health and safety. Equal protection requires equality among equals, and those who repeatedly fail the NMAT are not similarly situated to those who pass.

• Police Power — The inherent power of the State to enact regulations to promote the health, morals, peace, education, good order, safety, and general welfare of the people. Applied here to uphold the DECS rule limiting NMAT attempts as a measure to ensure the competence of medical professionals and protect public health. The Court found that the rule had a lawful subject (protection of public health by ensuring competent medical practitioners) and a lawful method (the three-flunk rule, which is not arbitrary or oppressive).
• Right to Quality Education — A constitutional right of every citizen to choose a profession or course of study, subject to fair, reasonable and equitable admission and academic requirements. The Court held this right is not absolute and must yield to reasonable state regulation, such as the NMAT three-flunk rule, designed to ensure standards in education and professional practice.
• Equal Protection Clause — A constitutional guarantee that all persons similarly circumstanced shall be treated alike, both in rights conferred and responsibilities imposed. The Court found no violation, stating that the rule applies equally to all who fail the NMAT three times and that a substantial distinction exists between medical students/profession and others, justifying stricter regulation for the former due to public health concerns.
• Due Process — A constitutional guarantee of fair treatment through the normal judicial system, especially as a citizen's entitlement. The Court implicitly found no violation of substantive due process, as the rule was deemed a reasonable exercise of police power, not arbitrary or oppressive.

• "The issue before us is mediocrity. The question is whether a person who has thrice failed the National Medical Admission Test (NMAT) is entitled to take it again."
• "It is the right and indeed the responsibility of the State to insure that the medical profession is not infiltrated by incompetents to whom patients may unwarily entrust their lives and health."
• "While every person is entitled to aspire to be a doctor, he does not have a constitutional right to be a doctor."
• "The Constitution also provides that 'every citizen has the right to choose a profession or course of study, subject to fair, reasonable and equitable admission and academic requirements.'"
• "There would be unequal protection if some applicants who have passed the tests are admitted and others who have also qualified are denied entrance. In other words, what the equal protection requires is equality among equals."
• "We cannot have a society of square pegs in round holes, of dentists who should never have left the farm and engineers who should have studied banking and teachers who could be better as merchants."
• "Otherwise, we may be 'swamped with mediocrity,' in the words of Justice Holmes, not because we are lacking in intelligence but because we are a nation of misfits."

• Tablarin v. Gutierrez, 152 SCRA 730 — Referenced as upholding the constitutionality of the NMAT itself as a measure to limit admission to medical schools to competent individuals. The Court extended the rationale of Tablarin to support the "three-flunk rule," as both concern the academic preparation and aptitude of applicants for medical studies.
• US v. Toribio, 15 Phil. 85 — Cited as an example of a case defining the valid exercise of police power (requiring lawful subject and lawful method).
• Fabie v. City of Manila, 21 Phil. 486 — Cited as an example of a case defining the valid exercise of police power.
• Ynot v. Intermediate Appellate Court, 148 SCRA 659 — Cited as an example of a case defining the valid exercise of police power.

• Article III, Section 1 of the Constitution (implied, regarding equal protection) — Referenced in the discussion of the equal protection clause, stating that a law does not have to operate with equal force on all persons or things to be conformable to this section.
• Article XIV, Section 5(3) of the Constitution — "Every citizen has a right to select a profession or course of study, subject to fair, reasonable, and equitable admission and academic requirements." Cited to emphasize that the right to choose a profession is not absolute and is subject to such requirements.
• MECS Order No. 12, Series of 1972, rule h) — The specific administrative rule being challenged, which states: "A student shall be allowed only three (3) chances to take the NMAT. After three (3) successive failures, a student shall not be allowed to take the NMAT for the fourth time." This rule was the central subject of the constitutional challenge.
• MECS Order No. 52, s. 1985 — Mentioned as articulating the rationale for regulating access to medical schools: the improvement of the professional and technical quality of medical graduates by upgrading the quality of those admitted.