GR L 78164; (July, 1987) (Digest)
G.R. No. L-78164; July 31, 1987
TERESITA TABLARIN, ET AL., petitioners, vs. THE HONORABLE JUDGE ANGELINA S. GUTIERREZ, ET AL., respondents.
FACTS
The petitioners, seeking admission into medical colleges for the 1987-1988 school year, either did not take or did not pass the National Medical Admission Test (NMAT). The NMAT was established by MECS Order No. 52, s. 1985, as an additional requirement for obtaining a certificate of eligibility for medical school admission, pursuant to the authority of the Board of Medical Education under the Medical Act of 1959 ( R.A. No. 2382 , as amended). The petitioners filed a Petition for Declaratory Judgment and Prohibition with the Regional Trial Court, seeking to enjoin the enforcement of the NMAT requirement. The trial court denied their petition for a preliminary injunction, and the NMAT was administered as scheduled. The petitioners then elevated the case to the Supreme Court via a special civil action for certiorari.
ISSUE
Whether the issuance of MECS Order No. 52, which prescribes the NMAT as a prerequisite for admission to medical schools, constitutes an invalid exercise of delegated legislative power and violates the petitioners’ constitutional rights.
RULING
The Supreme Court dismissed the petition and affirmed the trial court’s order. The Court upheld the validity of the NMAT requirement. It ruled that the Medical Act of 1959 validly delegated to the Board of Medical Education the authority to determine and prescribe requirements for admission into medical colleges, as explicitly stated in Section 5(a) of the law. This delegation is constitutional as it provides a sufficient standard: the standardization and regulation of medical education. The Court emphasized that the legislature may delegate rule-making authority to implement a law’s policies, especially where it is impracticable for Congress to anticipate all complex situations. The NMAT, as an aptitude test, is a germane instrument to upgrade the selection of applicants and improve the quality of medical education, which falls squarely within the law’s objective. The requirement was also deemed a valid exercise of the state’s police power to ensure that medical practitioners are competent, thereby protecting public health. It does not violate constitutional rights as the right to quality education is subject to reasonable regulation in the pursuit of a legitimate state interest.