G.R. No. 239350 , August 22, 2023
J. Paul Q. Octaviano, Petitioner, vs. Board of Architecture of the Professional Regulations Commission, Professional Regulations Commission and United Architects of the Philippines, Respondents.

FACTS

Republic Act No. 9266 (Architecture Act of 2004) mandated the integration of the architecture profession into one integrated and accredited professional organization (IAPOA). On May 19, 2004, United Architects of the Philippines (UAP) filed a petition for accreditation as the IAPOA. The Board of Architecture (Board) issued Resolution No. 03, Series of 2004, granting UAP’s petition, which the Professional Regulation Commission (PRC) approved. Subsequently, the Board issued Resolution No. 02, Series of 2005, requiring registered architects to submit valid UAP membership certificates and receipts for dues prior to the issuance or renewal of their Certificates of Registration and Professional Identification Cards. Later, the Board issued Resolution No. 05, Series of 2015, requiring successful licensure examinees to present proof of UAP membership dues payment prior to registration. Petitioner J. Paul Q. Octaviano filed a Petition for Declaratory Relief before the Regional Trial Court (RTC) seeking to declare these three Resolutions as invalid, illegal, and unenforceable for allegedly violating RA 9266 and the Constitution. The RTC dismissed the petition. The Court of Appeals affirmed the RTC’s decision, upholding the validity and constitutionality of the Resolutions. Octaviano elevated the case via a Petition for Review on Certiorari.

ISSUE

The primary issue is whether the Board Resolutions (No. 03, Series of 2004; No. 02, Series of 2005; and No. 05, Series of 2015) are valid and constitutional.

RULING

The Supreme Court denied the petition and affirmed the assailed Court of Appeals Decision and Resolution. The Court held that the Resolutions were validly issued pursuant to the regulatory power of the State and the specific mandates of RA 9266.
1. On Resolution No. 03, Series of 2004 (Accreditation of UAP): The Court ruled that the accreditation of UAP as the IAPOA was valid. It found that the procedure followed complied with Section 40 of RA 9266. The law does not require the creation of a new organization; an existing organization can be accredited. The requirement for registration with the Securities and Exchange Commission is a precondition for an organization to be considered for accreditation, not a step to be undertaken after accreditation. UAP, being already registered, satisfied this requirement. The accreditation did not violate the equal protection clause as it was based on a reasonable classification (UAP was the only organization that applied for accreditation) and was germane to the purpose of the law (integrating the profession).
2. On Resolutions No. 02, Series of 2005 and No. 05, Series of 2015 (Compulsory Membership and Payment of Dues): The Court ruled that these Resolutions were valid implementations of RA 9266. The law mandates integration into one IAPOA, which necessarily implies compulsory membership. The power to require membership and payment of dues is inherent in the regulatory authority of the State over professions, aimed at ensuring public welfare and the continuous development of the profession. The Resolutions did not constitute an invalid delegation of legislative power; they were issued by the administrative body (the Board) pursuant to its explicit rule-making authority under RA 9266 to carry out the provisions of the law, including the integration mandate. The requirement to pay membership dues as a precondition for registration or renewal is a reasonable regulation incidental to the practice of the profession and does not impair any vested right.
In conclusion, the Resolutions were issued within the confines of RA 9266 and are not contrary to the Constitution.