GR 112844; (June, 1995) (Digest)
G.R. No. 112844, June 2, 1995
PHILIPPINE MERCHANT MARINE SCHOOL, INC., represented by JUAN O. NOLASCO III, petitioner, vs. COURT OF APPEALS, THE OFFICE OF THE EXECUTIVE SECRETARY, EDELMIRO AMANTE, RENATO CORONA, and the DEPARTMENT OF EDUCATION, CULTURE AND SPORTS, respondents.
FACTS
The Philippine Merchant Marine School, Inc. (PMMSI) operated maritime courses in Manila. For several years prior to 1985, the Department of Education, Culture and Sports (DECS) disapproved its requests for permit renewal. Although a renewal permit was issued for SY 1985-1986 and a conditional summer permit for 1986, DECS later received complaints about PMMSI operating courses without government recognition. DECS investigations revealed PMMSI’s persistent failure to secure the necessary permits for subsequent school years and its non-compliance with directives to explain its operations and correct deficiencies. Despite warnings, PMMSI continued to enroll students without a permit.
DECS inspections in 1988 and 1989 found PMMSI severely deficient, scoring far below minimum standards for facilities and equipment as mandated by DECS policies. The DECS Technical Panel for Maritime Education recommended a gradual phase-out of its programs. The Office of the President, upon appeal, sustained DECS’s actions. PMMSI then filed a petition for certiorari with the Court of Appeals, which was dismissed, prompting this appeal to the Supreme Court.
ISSUE
Whether the Court of Appeals erred in upholding the resolutions of the Office of the President which sustained the DECS’s order for the phase-out and non-issuance of permits to PMMSI.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals. The Court emphasized that the issuance of permits and recognition to educational institutions, and the determination of compliance with prescribed standards, are primarily executive functions vested in the DECS Secretary. Judicial review is limited to determining whether the administrative agency acted within its jurisdiction or with grave abuse of discretion. The Court found no such abuse.
The records established that PMMSI repeatedly operated without the required permits and consistently failed to meet the minimum standards for maritime education over many years, despite being given opportunities to comply. The DECS’s findings of gross deficiencies were based on thorough inspections and were afforded due process. The phase-out order was a reasonable exercise of the state’s regulatory power to protect students and maintain the quality of education. Since the administrative actions were grounded on substantial evidence and within the bounds of the law, the Court upheld the doctrine of primary jurisdiction, refusing to substitute its judgment for the expertise of the DECS on technical educational standards.