G.R. No. 144681 ; June 21, 2004
Professional Regulation Commission (PRC), et al., petitioners, vs. Arlene V. De Guzman, et al., respondents.

FACTS

The respondents, all graduates of Fatima College of Medicine, passed the February 1993 Physician Licensure Examination. The Board of Medicine observed that their scores in Biochemistry and Obstetrics-Gynecology were exceptionally and unusually high, with many achieving near-perfect grades, a phenomenon unprecedented and isolated to Fatima examinees. Consequently, the Board issued Resolution No. 19, withholding their registration. A statistical analysis by an expert and an NBI investigation suggested the scores indicated possible prior access to test questions. The Board later charged the respondents with immorality and dishonesty, recommending nullification of their results.
The respondents filed a special civil action for mandamus with the Regional Trial Court (RTC) to compel the PRC to administer their oaths and register them as physicians. The RTC granted a preliminary mandatory injunction, which was later nullified by the Court of Appeals. The RTC subsequently rendered a judgment in favor of the respondents, which the Court of Appeals affirmed, leading to this petition.

ISSUE

Whether the Court of Appeals erred in affirming the RTC’s decision that allowed the respondents to take their physician’s oath and register as licensed doctors despite the administrative charges for alleged fraud in the licensure examinations.

RULING

The Supreme Court granted the petition, reversing the Court of Appeals. The legal logic centers on the distinction between the power to pass an examination and the discretionary authority to confer a license. While passing the exam is a prerequisite, the right to a license is not automatic. The PRC and the Board, under their regulatory mandate, possess the authority to investigate examinees and withhold registration upon finding evidence of fraud or dishonesty.
The Court held that the administrative case (Adm. Case No. 1687) filed by the Board against the respondents was the proper proceeding to determine their moral fitness. The RTC’s grant of mandamus was premature as it preempted this ongoing administrative process. Mandamus lies only to compel a ministerial duty, not a discretionary act. The act of registration and oath-taking becomes ministerial only after the administrative body has favorably resolved the question of the applicant’s moral character and fitness. Since the administrative charges were pending, the PRC’s duty to register the respondents was not yet clear and indisputable. Therefore, the lower courts erred in ordering the issuance of the license without waiting for the final outcome of the administrative investigation into the alleged irregularities.