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). The initial and subsequent surveys consistently found the College deficient in critical areas: it lacked a university affiliation and a base hospital for clinical training; over 60% of its faculty were not full-time, leading to poor teaching quality; its student credentials and preparedness were subpar; and it failed to fulfill its avowed purpose of focusing on Muslim health welfare. Despite opportunities for improvement, follow-up inspections confirmed these serious deficiencies. Based on these findings, the BME recommended closure, which was affirmed by the DECS Secretary and later by the Office of the President.
The College then filed a civil case in the Regional Trial Court of Antipolo, Rizal, assailing the closure order as arbitrary and discriminatory. It claimed the final inspection in June 1988 was conducted by a biased team that had already prejudged the school. The trial court, presided by Judge Daniel P. Alfonso, issued a writ of preliminary injunction restraining the enforcement of the closure order. This prompted the BME and the DECS Secretary to file the instant petition for certiorari before the Supreme Court.

ISSUE

Whether the Regional Trial Court gravely abused its discretion in issuing the writ of preliminary injunction against the administrative closure order issued by the Board of Medical Education and the DECS Secretary.

RULING

Yes, the Regional Trial Court committed grave abuse of discretion. The Supreme Court granted the petition, set aside the injunction, and ordered the dismissal of the civil case. The Court emphasized that the authority to prescribe standards for and regulate the operation of medical schools is vested by law in the Department of Education, Culture and Sports and the Board of Medical Education. Their findings of fact, especially when affirmed by the Office of the President, are generally conclusive if supported by substantial evidence. In this case, the closure decision was based not on a single inspection but on a series of evaluations conducted over more than three years, all of which uniformly found the College grossly deficient.
The trial court exceeded its jurisdiction by substituting its own judgment for that of the administrative agencies on the technical and specialized question of whether the College met the prescribed standards. Judicial review is limited to determining whether the administrative body acted within its jurisdiction or committed grave abuse of discretion. The consistent findings of multiple inspection teams constituted more than sufficient substantial evidence to support the administrative action. Therefore, the trial court had no legal basis to interfere with the final and executory administrative order of closure. The injunction was improperly issued, as it undermined the regulatory prerogative of the BME and DECS to ensure the quality of medical education in the country.