36 - Board of Medical Education v. Alfonso, G.R. No. 88259, August 10, 1989

36. Board of Medical Education vs. Alfonso GR No.
88259 August 10, 1989

FACTS:
The, College, a private educational institution, was founded in 1981 for the avowed
purpose of producing physicians who will “emancipate Muslim citizens from age-old
attitudes on health.” The, unstable peace and order situation in Mindanao led to the
establishment of the College in Antipolo, Rizal, which granted it a temporary permit to
operate in the municipality, instead of in Zamboanga City where the school was first
proposed to be located. It has since adopted Antipolo as its permanent site and changed
its name to the Rizal College of Medicine.
In 1985, the Department of Education, Culture and Sports (DECS) and the Board of
Medical Education (BME) authorized the Commission on Medical Education to conduct
a study of all medical schools in the Philippines. The report of the Commission showed
that the College fell very much short of the minimum standards set for medical schools.
The team of inspectors recommended the closure of the school upon the following
findings, to wit:
(a) the College was not fulfilling the purpose for which it had been created because of its
inappropriate location and the absence in its curriculum of subjects relating to Muslim
culture and welfare;
(b) its lack of university affiliation hindered its students from obtaining a “balanced
humanistic and scientific” education;
(c) it did not have its philosophy base hospital for the training of its students in the major
clinical disciplines, as required by the DECS;
(d) more than 60% of the college faculty did not teach in the College full-time, resulting
in shortened and irregular class hours, subject overloading, and in general, poor quality
teaching.
The school disputed these findings as biased and discriminatory. Four (4) other surveys
were thereafter made by as many different committees or teams, at the school’s instance
or otherwise, all of which basically confirmed the results of that first survey.
In her letter of June 23, 1988, Secretary Quisumbing informed the Chairman of the
College’s Board of Trustees, Mr. Victor Sumulong, of the decision of the Board of Medical
Education to close the College. Mr. Sumulong instead proposed a gradual phase-out
starting the school year 1989-1990 in order not to dislocate the students and staff and to
minimize financial loss. The Board subsequently allowed the College to continue its
operations but only until May 1989, after which it was to be closed, this decision being
“final and unappealable.”
The College appealed the decision to the Office of the President, imputing grave abuse of
discretion to the Secretary. On February 16, 1989, Executive Secretary Catalino Macaraig,
Jr., finding “no reason to disturb” the contested decision, affirmed it.
On March 2, 1989, the College went to court. It filed Civil Case No. 1385 in the court of
respondent Judge Daniel P. Alfonso against Secretary Quisumbing in her capacity as
Secretary of Education, Culture and Sports, questioning the decision as illegal,
oppressive, arbitrary and discriminatory and applied for a writ of preliminary injunction
to restrain its implementation. The writ was issued as prayed for, by order of the
respondent Judge dated May 10, 1989, ruled that the inspection of June 18, 1988 was the
principal basis of the closure order, and on such basis sustained the claim of the College
that the inspection was done in an “arbitrary and haphazard manner” by a team of
inspectors who had already prejudged the school.
ISSUE:
WON the order of injunction dated May 10, 1989 was issued with grave abuse of discretion
and a restraining order against its enforcement as well as for the dismissal of the action
may be instituted in the court a quo.
HELD:
Yes. The order of injunction dated May 10, 1989 was issued with grave abuse of discretion
and a restraining order against its enforcement as well as for the dismissal of the action
may be instituted in the court a quo.
Respondent Judge gravely abused his discretion in substituting his judgment for theirs.
It is well-settled doctrine that courts of justice should not generally interfere with purely
administrative and discretionary functions; that courts have no supervisory power over
the proceedings and actions of the administrative departments of the government;
involving the exercise of judgment and findings of facts, because by reason of their special
knowledge and expertise over matters falling under their jurisdiction, the latter are in a
better position to pass judgment on such matters and in their findings of facts in that
regard are generally accorded respect, if not finality, by the courts. There are, to be sure,
exceptions to this general rule but none of them obtains in this case.

36 - Board of Medical Education v. Alfonso, G.R. No. 88259, August 10, 1989

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36. Board of Medical Education vs. Alfonso GR No.

88259 August 10, 1989

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