G.R. No. 40100 ; September 6, 1933
THE PEOPLE OF THE PHILIPPINE ISLANDS, plaintiff-appellee, vs. GUALBERTO SANTOS, defendant-appellant.

FACTS

The defendant, Gualberto Santos, is a licensed physician who paid the corresponding privilege tax for practicing medicine. In 1931, he publicly advertised himself as a “medico-dentista,” extracted and treated teeth, placed crowns, and received payment for these dental services. He was convicted in the trial court for violating sections 1453 and 1473(c) of the Administrative Code for practicing dentistry without a certificate of registration as a dentist and without paying the specific privilege tax for dentistry.

ISSUE

Whether a holder of a license to practice medicine who has paid the corresponding privilege tax is entitled to practice dentistry without first obtaining a certificate of registration as a dentist and paying the privilege tax therefor.

RULING

No. The Supreme Court affirmed the conviction. The Court ruled that the Philippine Legislature enacted distinct laws regulating the practice of medicine and dentistry, each with specific registration and taxation requirements. While the professions may overlap, the legislative intent was to treat them as separate for reasons of public policy, requiring special preparation, licensing, and taxation for dentistry. A physician must comply with the Dental Law’s registration and tax requirements to legally practice dentistry. The Court adopted the reasoning of State of Minnesota vs. Taylor, which held the two professions separate, over the contrary view in State of Rhode Island vs. Beck.

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