G.R. No. 88259 August 10, 1989
THE BOARD OF MEDICAL EDUCATION and the HON. LOURDES R. QUISUMBING, in her capacity as Secretary of the Department of Education, Culture and Sports and Chairman, Board of Medical Education, petitioners, vs. HON. DANIEL P. ALFONSO, Presiding Judge of the Regional Trial Court, Branch 74, Fourth Judicial Region, Antipolo, Rizal, and the PHILIPPINE MUSLIM-CHRISTIAN COLLEGE OF MEDICINE FOUNDATION, INC., respondents.

FACTS

The Philippine Muslim-Christian College of Medicine Foundation, Inc. (the College) was a private medical school. From 1985 to 1988, it underwent a series of evaluations by inspection teams from the Board of Medical Education (BME). Multiple reports consistently found the College deficient in critical areas: it lacked a university affiliation and a base hospital for clinical training; its faculty was largely part-time, leading to poor teaching quality; its student profile was below par; and it showed no serious academic development philosophy. Despite opportunities for improvement, successive inspections confirmed these serious shortcomings. Based on these findings, the BME recommended closure, and DECS Secretary Lourdes Quisumbing issued a closure order effective May 1989.
The College filed a petition with the Regional Trial Court of Antipolo, Rizal, alleging the closure order was arbitrary and the inspections were biased. It secured a writ of preliminary injunction from Judge Daniel P. Alfonso, restraining the enforcement of the closure. The injunction was based on the court’s finding that the inspectors had prejudged the school and that the final inspection was conducted in a haphazard manner. The BME and Secretary Quisumbing elevated the case to the Supreme Court via certiorari.

ISSUE

Whether the Regional Trial Court gravely abused its discretion in issuing the writ of preliminary injunction against the administrative closure order of the BME and the DECS Secretary.

RULING

Yes, the Supreme Court ruled that the Regional Trial Court committed grave abuse of discretion. The Court emphasized that the issuance of a preliminary injunction against the execution of a final administrative decision is a judicial power that must be exercised with utmost caution and only under exceptional circumstances. The administrative decision in this case, affirming the closure of the medical school, was rendered by the DECS Secretary and affirmed by the Office of the President. It was therefore a final order, issued by the competent authority in the exercise of its quasi-judicial functions and regulatory power over educational institutions.
The trial court overstepped its jurisdiction by substituting its own judgment for that of the administrative agency on the technical and factual issue of whether the College met the prescribed standards for medical education. The authority to determine compliance with minimum standards for medical schools is vested by law in the DECS and the BME, not in the courts. The Supreme Court found that the administrative process was exhaustive, involving multiple inspections over several years, which consistently revealed the College’s failure to comply. The trial court’s finding of arbitrariness was unsupported, as the inspectors were qualified experts, and their repeated, consistent findings constituted substantial evidence. Consequently, the injunction improperly interfered with a final administrative act, and the petition for certiorari was granted. The writ of injunction was set aside, and the trial court was ordered to dismiss the civil case.