PRC vs. De Guzman, G. R. No.

144681, June 21,

2004
Constitutional Law: Police PowerFacts:
The respondents are all graduates of the Fatima College of Medicine, Valenzuela
City, Metro Manila. They passed the Physician Licensure Examination conducted in
February 1993 by the Board of Medicine (Board).
Petitioner Professional Regulation Commission (PRC) then released their names as
successful examinees in the medical licensure examination.Shortly thereafter, the
Board observed that the grades of the seventy-nine successful examinees from
Fatima Collegein the two most difficult subjects in the medical licensure exam,
Biochemistry (Bio-Chem) and Obstetrics and Gynecology (OB-Gyne), were unusually
and exceptionally high. Eleven Fatima examinees scored 100% in Bio-Chem and ten
got 100% in OB-Gyne, another eleven got 99% in Bio-Chem, and twenty-one scored
99% in OB-Gyne. The Board also observed that many of those who passed from
Fatima got marks of 95% or better in both subjects, and no one got a mark lower
than 90%.
A comparison of the performances of the candidates from other schools was made.
The Board observed that strangely, the unusually high ratings were true only for
Fatima College examinees. It was a record-breaking phenomenon in the history of
the Physician Licensure Examination.For its part, the NBI found that the
questionable passing rate of Fatima examinees in the [1993] Physician Examination
leads to the conclusion that the Fatima examinees gained early access to the test
questions.
The Board issued Resolution No. 26, dated July 21, 1993, charging respondents with
"immorality, dishonest conduct, fraud, and deceit" in connection with the Bio-Chem
and Ob-Gyne examinations. It recommended that the test results of the Fatima
examinees be nullified. Trial courts judgment is rendered ordering the respondents
to allow the petitioners and intervenors to take the physicians oath and to register
them as physicians without prejudice to any administrative disciplinary action which
may be taken against any of the petitioners for such causes and in the manner
provided by law and consistent with the requirements of the Constitution as any
other professionals.Issue: Whether or not the act pursuant to R.A. 2382 known as
The Medical Act of 1959 a valid exercise of police power.
Held:Yes. It is true that this Court has upheld the constitutional right of every citizen
to select a profession or course of study subject to a fair, reasonable, and equitable
admission and academic requirements. But like all rights and freedoms guaranteed
by the Charter, their exercise may be so regulated pursuant to the police power of
the State to safeguard health, morals, peace, education, order, safety, and general
welfare of the people. Thus, persons who desire to engage in the learned

professions requiring scientific or technical knowledge may be required to take an

examination as a prerequisite to engaging in their chosen careers.
This regulation takes particular pertinence in the field of medicine, to protect the
public from the potentially deadly effects of incompetence and ignorance among
those who would practice medicine.
It must be stressed, nevertheless, that the power to regulate the exercise of a
profession or pursuit of an occupation cannot be exercised by the State or its agents
in an arbitrary, despotic, or oppressive manner. A political body that regulates the
exercise of a particular privilege has the authority to both forbid and grant such
privilege in accordance with certain conditions. Such conditions may not, however,
require giving up ones constitutional rights as a condition to acquiring the license.

PRC vs. De Guzman

Facts: The respondents are all graduates of the Fatima College of Medicine,
Valenzuela City, Metro Manila. They passed the Physician Licensure Examination
conducted in February 1993 by the Board of Medicine (Board). Petitioner
Professional Regulation Commission (PRC) then released their names as successful
examinees in the medical licensure examination. Shortly thereafter, the Board
observed that the grades of the seventy-nine successful examinees from Fatima
College in the two most difficult subjects in the medical licensure exam,
Biochemistry (Bio-Chem) and Obstetrics and Gynecology (OB-Gyne), were unusually
and exceptionally high. Eleven Fatima examinees scored 100% in Bio-Chem and ten
got 100% in OB-Gyne, another eleven got 99% in Bio-Chem, and twenty-one scored
99% in OB-Gyne.
For its part, the NBI found that the questionable passing rate of Fatima examinees
in the [1993] Physician Examination leads to the conclusion that the Fatima
examinees gained early access to the test questions.
Issue: Was the act pursuant to R.A. 2382 a valid exercise of police power
Ruling: Yes, it is true that this Court has upheld the constitutional right of every
citizen to select a profession or course of study subject to a fair, reasonable, and
equitable admission and academic requirements. But like all rights and freedoms
guaranteed by the Charter, their exercise may be so regulated pursuant to the
police power of the State to safeguard health, morals, peace, education, order,
safety, and general welfare of the people. Thus, persons who desire to engage in
the learned professions requiring scientific or technical knowledge may be required
to take an examination as a prerequisite to engaging in their chosen careers

LUZ FARM VS. DAR

University of the Philippines College of Law
Constitutional Law 1 | Professor Charlemagne Yu
Case Digest
TOPIC: Reform in Agricultural and Natural Resources
DOCTRINE:
CASE Number (including date): [G.R. No. 86889 : December 4, 1990.]
CASE Name: LUZ FARMS, Petitioner, vs. THE HONORABLE SECRETARY OF THE
DEPARTMENT OF AGRARIAN REFORM, Respondent.
Ponente: Paras, J.

FACTS
Petition for prohibition with prayer for restraining order and/or
preliminary and permanent injunction against the Honorable Secretary
of the Department of Agrarian Reform for acting without jurisdiction in
enforcing the assailed provisions of R.A. No. 6657
On June 10, 1988, the President of the Philippines approved R.A. No. 6657,
which includes the raising of livestock, poultry and swine in its coverage
On January 2, 1989, the Secretary of Agrarian Reform promulgated the
Guidelines and Procedures Implementing Production and Profit Sharing as
embodied in Sections 13 and 32 of R.A. No. 6657
On January 9, 1989, the Secretary of Agrarian Reform promulgated its Rules
and Regulations implementing Section 11 of R.A. No. 6657 (Commercial
Farms)
Luz Farms is a corporation engaged in the livestock and poultry business and
allegedly stands to be adversely affected by the following provisions in R.A.
No. 6657
o (a) Section 3(b) which includes the "raising of livestock (and poultry)"
in the definition of "Agricultural, Agricultural Enterprise or Agricultural
Activity."
o (b) Section 11 which defines "commercial farms" as "private
agricultural lands devoted to commercial, livestock, poultry and
swine raising . . ."
o (c) Section 13 which calls upon petitioner to execute a productionsharing plan.
o (d) Section 16(d) and 17 which vest on the Department of Agrarian
Reform the authority to summarily determine the just compensation to
be paid for lands covered by the Comprehensive Agrarian Reform Law.

(e) Section 32 which spells out the production-sharing plan mentioned

in Section 13
". . . (W)hereby three percent (3%) of the gross sales from the
production of such lands are distributed within sixty (60) days of
the end of the fiscal year as compensation to regular and other
farmworkers in such lands over and above the compensation
they currently receive: Provided, That these individuals or
entities realize gross sales in excess of five million pesos per
annum unless the DAR, upon proper application, determine a
lower ceiling.
In the event that the individual or entity realizes a profit, an
additional ten (10%) of the net profit after tax shall be
distributed to said regular and other farmworkers within ninety
(90) days of the end of the fiscal year . . ."
Luz Farms does not seek to nullify the whole act; it merely contends that the
Acts provisions with regard to livestock and poultry transcended its
constitutional mandate
Respondent cited Webster's International Dictionary, Second Edition (1954):
"Agriculture the art or science of cultivating the ground and raising and
harvesting crops, often, including also, feeding, breeding and management of
livestock, tillage, husbandry, farming
o

ISSUES
1 Whether or not livestock and poultry lands should be included in
agrarian reform.
2 Whether or not the aforementioned provisions are constitutional,
insofar as the said law includes the raising of livestock, poultry and swine in
its coverage as well as the Implementing Rules and Guidelines promulgated
in accordance therewith.

HELD (including the Ratio Decidendi)

(1) No: The transcripts of the deliberations of the Constitutional Commission
of 1986 on the meaning of the word "agricultural," clearly show that it was
never the intention of the framers of the Constitution to include livestock and
poultry industry in the coverage of the constitutionally-mandated agrarian
reform program of the Government. "Sa pangalawang katanungan ng Ginoo
ay medyo hindi kami nagkaunawaan. Ipinaaalam ko kay Commissioner
Regalado na hindi namin inilagay ang agricultural worker sa kadahilanang
kasama rito ang piggery, poultry at livestock workers. Ang inilagay namin dito
ay farm worker kaya hindi kasama ang piggery, poultry at livestock workers
Commissioner Tadeos statement
(2) No: Sections 13 and 32 of R.A. 6657 directing "corporate farms" which
include livestock and poultry raisers to execute and implement "productionsharing plans" (pending final redistribution of their landholdings) whereby
they are called upon to distribute from three percent (3%) of their gross sales

and ten percent (10%) of their net profits to their workers as additional
compensation is unreasonable for being confiscatory, and therefore violative
of due process
RULING:
PREMISES CONSIDERED, the instant petition is hereby GRANTED. Sections 3(b), 11,
13 and 32 of R.A. No. 6657 insofar as the inclusion of the raising of livestock, poultry
and swine in its coverage as well as the Implementing Rules and Guidelines
promulgated in accordance therewith, are hereby DECLARED null and void for being
unconstitutional and the writ of preliminary injunction issued is hereby MADE
permanent.