G.R. No. L-77372. April 29, 1988.
LUPO L. LUPANGCO, ET AL., petitioners, vs. COURT OF APPEALS and PROFESSIONAL REGULATION COMMISSION, respondents.

FACTS

The Professional Regulation Commission (PRC) issued Resolution No. 105, prohibiting examinees for the accountancy licensure exams from attending any review class or receiving any review materials during the three days immediately preceding each examination day. Petitioners, who were reviewees set to take the exams, filed a complaint for injunction with the Regional Trial Court (RTC) of Manila, seeking to restrain the PRC from enforcing the resolution and to declare it unconstitutional. The RTC assumed jurisdiction and enjoined the enforcement of the resolution.
The PRC filed a motion to dismiss, challenging the RTC’s jurisdiction. The Court of Appeals granted the PRC’s subsequent petition, nullifying the RTC’s order and directing the dismissal of the civil case. The appellate court ruled that the PRC and the RTC are co-equal bodies; thus, the RTC cannot interfere with the PRC’s administrative acts. This decision prompted the petitioners to elevate the case to the Supreme Court.

ISSUE

The primary issues are: (1) Whether the Regional Trial Court has jurisdiction to review and enjoin the enforcement of PRC Resolution No. 105; and (2) Whether Resolution No. 105 is constitutional.

RULING

The Supreme Court reversed the Court of Appeals and declared Resolution No. 105 null and void. On jurisdiction, the Court held that the RTC properly exercised its general jurisdiction. The doctrine of co-equality invoked by the appellate court was misplaced, as it specifically pertained to agencies like the Securities and Exchange Commission, whose enabling laws provide for direct appeal to the Supreme Court, thereby excluding lower court review. No such exclusive appellate procedure is provided in Presidential Decree No. 223, the law creating the PRC. Consequently, the RTC, under its general jurisdiction over cases not within the exclusive jurisdiction of any other tribunal, could properly take cognizance of the action assailing the PRC’s resolution.
On the merits, the Court ruled the resolution unconstitutional. While the PRC has the authority to promulgate rules for the conduct of licensure examinations to preserve their integrity, the prohibition was deemed unreasonable and a violation of the examinees’ right to liberty. The sweeping ban on all review activities three days before the exams, including legitimate study and receipt of non-confidential materials, bore no reasonable relation to the objective of preventing leaks. It unduly restricted the examinees’ freedom to prepare and effectively impaired their right to pursue a profession. The Court emphasized that the PRC should address examination leaks directly by investigating and punishing the culpable parties, not by curtailing the legitimate review rights of all examinees. The resolution was thus declared an invalid exercise of police power.