GR L 7262; (October, 1911) (CRITIQUE)
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THE AI-ASSISTED CRITIQUE
The court’s reasoning in Gonzales v. Board of Pharmacy correctly identifies the strict statutory construction of Act No. 597 but fails to adequately address the potential for an arbitrary and capricious denial of a vested professional right. The plaintiff presented a compelling case of equitable excusability—his isolation in Negros and lack of notice of the 120-day registration deadline under Section 11. However, the court rigidly enforces the statutory time limit, treating it as a mandatory and jurisdictional prerequisite without applying principles of lex non cogit ad impossibilia—the law does not require the impossible. This formalistic approach ignores the transitional nature of the law following the change of sovereignty and the plaintiff’s established, lawful practice under the prior Spanish regime, effectively penalizing him for circumstances beyond his control without a clear legislative intent to extinguish such existing rights so harshly.

The decision’s reliance on the distinction between graduates of the University of Santo Tomas (exempt from examination under Sections 9-10) and other qualified pharmacists like the plaintiff is legally sound but highlights a legislative classification that may be questioned. The court properly notes that the plaintiff, a graduate of the College of Pharmacy of Spain, does not fall within the express grandfather clauses for Santo Tomas graduates. Yet, the opinion does not critically examine whether this distinction bears a rational relationship to the law’s objective of ensuring pharmacist competency, given the plaintiff’s proven qualifications and prior licensed practice. The court defers entirely to the police power of the legislature without scrutinizing if the statutory scheme, as applied, creates an irrational or overly broad exclusion that could violate substantive due process by depriving a person of a lawful livelihood without a reasonable opportunity for compliance.

Ultimately, the court’s denial of the writ of mandamus is procedurally correct, as the plaintiff failed to meet the unambiguous condition precedent of timely registration, and the Board’s duty to issue a certificate was not “clear” under the law’s terms. However, the critique rests on the court’s missed opportunity to interpret Section 11 more flexibly or to recognize a ministerial duty triggered by the plaintiff’s subsequent attempt to register, given his prima facie qualifications. By treating the deadline as absolute, the decision elevates procedural finality over substantive fairness, setting a precedent that could validate administrative inflexibility in future regulatory transitions. The court could have balanced statutory obedience with equitable considerations, perhaps by remanding for the Board to exercise any discretionary authority it might possess, rather than endorsing a refusal that appears unduly harsh under the specific facts alleged.