Primary Holding
The Supreme Court upheld the constitutionality of the "three-flunk rule" (MECS Order No. 12, Series of 1972), stating it was a valid exercise of police power to regulate the medical profession and did not violate the right to education or equal protection.
Background
The case arose from the DECS's rejection of San Diego's application to take the NMAT for the fourth time, citing the "three-flunk rule". San Diego challenged this decision in court, arguing it infringed on his constitutional rights.
History
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San Diego, after failing the NMAT thrice, was denied a fourth attempt. He filed a petition for mandamus, initially invoking his right to education. Later, he amended the petition to challenge the constitutionality of the "three-flunk rule". The Regional Trial Court ruled in favor of San Diego, but this decision was reversed by the Supreme Court.
Facts
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Roberto Rey C. San Diego, a graduate of the University of the East with a degree in Zoology, had taken and failed the NMAT three times. His application to take the test a fourth time was rejected by DECS based on the "three-flunk rule".
Arguments of the Petitioners
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DECS argued that the "three-flunk rule" was a valid exercise of police power to regulate the medical profession, ensuring only qualified individuals become doctors and protecting public health and safety.
Arguments of the Respondents
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San Diego argued that the rule violated his constitutional rights to quality education, academic freedom, due process, and equal protection, asserting his persistence showed his passion for the medical profession.
Issues
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Whether the "three-flunk rule" violated the right to quality education and academic freedom.
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Whether the rule was a valid exercise of police power.
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3.
Whether the rule violated the equal protection clause.
Ruling
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1.
The Supreme Court ruled that the "three-flunk rule" was constitutional. It held that the right to quality education was not absolute and could be regulated for public welfare. The Court considered the rule a reasonable measure to ensure only qualified individuals entered the medical profession, safeguarding public health. The Court also found the rule did not violate equal protection as it applied to all applicants to medical schools, a group with distinct characteristics justifying the regulation.
Doctrines
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Police Power: The inherent power of the state to regulate behavior and enforce order within its territory for the betterment of the health, safety, morals, and general welfare of its inhabitants.
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Equal Protection Clause: Part of the Fourteenth Amendment to the U.S. Constitution that prohibits states from denying any person within their jurisdiction the equal protection of the laws.
Key Excerpts
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"The right to quality education invoked by the private respondent is not absolute."
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"A person cannot insist on being a physician if he will be a menace to his patients."
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"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."
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"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."
Precedents Cited
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Tablarin v. Gutierrez: Upheld the constitutionality of the NMAT as a measure to limit admission to medical schools to those with proven competence.
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US v. Toribio, Fabie v. City of Manila, Ynot v. Intermediate Appellate Court: Cited as examples of the State's police power.
Statutory and Constitutional Provisions
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Article III, Section 1 of the Constitution (Equal Protection Clause)
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Article XIV, Section 5(3) of the Constitution (Right to Quality Education)