327 Cases Penned by Associate Justice Amy Lazaro-Javier: 2025 Bar Examination
Can the Professional Regulation Commission (PRC)
unilaterally recognize the President of a professional organization such as the
Philippine Society of Mechanical Engineers (PSME) for purposes of issuing
professional certificates, without overstepping its regulatory authority?
Professional Regulation Commission vs. Philippine Society
of Mechanical Engineers (PSME)
G.R. No. 254282, September 14, 2021
Facts of the Case:
This case stems from a dispute within the Philippine Society
of Mechanical Engineers (PSME) over the election results of its 2016 National
Board of Directors and National Officers. During the PSME's 63rd National
Convention in October 2015, fifteen members were elected to the Board of
Directors, which was responsible for selecting the National Officers, including
the National President.
A dispute arose when Engr. Leandro Conti filed a protest,
alleging various irregularities, including the acceptance of late ballots and
voter list discrepancies. The PSME Commission on Elections (PSME-COMELEC)
annulled votes from the NCR Chapter and declared Engr. Conti’s group as winners
of the 2016 Board of Directors election.
On November 25, 2015, Engr. Conti was elected as PSME
National President by the PSME-COMELEC, but the outgoing PSME Board of
Directors proceeded with its own elections on November 28, 2015, declaring
Engr. Murry F. Demdam as the President.
The dispute continued, and the Professional Regulation
Commission (PRC) recognized Engr. Conti as the National President via Office
Order No. 2016-56, which allowed only certificates of good standing issued by
Engr. Conti to be used for the renewal of professional licenses. Engr. Demdam's
group filed a petition before the Regional Trial Court (RTC) of Manila, seeking
to nullify the PRC's recognition of Engr. Conti as PSME President.
The RTC dismissed the petition on the grounds of mootness,
citing a related intra-corporate case (RTC Manila-Br. 24), which voided the
election of Engr. Conti as National President. On appeal, the Court of Appeals
reversed the RTC’s decision, holding that the RTC erred in dismissing the case
because the issue of whether PRC had the authority to recognize Engr. Conti as
President remained unresolved. The Court of Appeals remanded the case for
resolution on the merits.
Issue at the Supreme Court:
Was the petition for declaration of nullity of PRC Office
Order No. 2016-56 moot in light of the RTC Manila-Br. 24's decision voiding
Engr. Conti’s election as PSME National President?
Supreme Court Decision:
The Supreme Court ruled that the petition was moot. The
Court explained that the controversy surrounding the PRC’s recognition of Engr.
Conti as PSME National President had been rendered irrelevant by the decision
of RTC Manila-Br. 24, which voided Conti’s election. As such, there was no
longer a justiciable issue regarding the validity of PRC Office Order No.
2016-56. The Court also noted that the PRC's Office Order was only provisional
and meant to prevent disruptions in the issuance of certificates of good
standing necessary for license renewals. Since the issue of leadership within
the PSME had been resolved, the PRC’s recognition of Engr. Conti had ceased to
have any practical effect.
Dispositive Portion:
The Supreme Court granted the petition of the Professional
Regulation Commission, setting aside the Court of Appeals’ decision and
dismissing the case as moot:
“ACCORDINGLY, the petition is GRANTED. The Decision dated
March 10, 2020 and Resolution dated September 21, 2020 of the Court of Appeals
in CA-G.R. CV No. 110943 are REVERSED and SET ASIDE. Civil Case No. 16-135469
entitled ‘Philippine Society of Mechanical Engineers represented by its
incumbent President Murry F. Demdam v. Professional Regulation Commission
Acting Chairperson Angeline T. Chua Chiaco Commissioner Yolanda Reyes’ is
DISMISSED for being moot.”
Thought-Provoking Question:
Should government agencies have the authority to
intervene in the internal affairs of private organizations, even if it is to
ensure the continuity of public services like professional license renewals?
Doctrines:
- Mootness
Doctrine
A case becomes moot when no actual controversy exists, and a court's decision will no longer have practical legal effect. Courts generally dismiss such cases unless exceptional circumstances warrant their resolution. - Res
Judicata
Res judicata bars further litigation of a case when a prior decision has already conclusively resolved the matter between the same parties, based on the same cause of action. - Regulatory
Powers of the PRC
The PRC’s role in professional organizations is limited to regulating the practice of professions and issuing licenses. It cannot unilaterally determine leadership within a professional organization unless it pertains directly to its regulatory mandate, such as the issuance of certificates required for license renewal.
- Administrative
Actions and Provisional Orders
Government agencies, like the PRC, may issue provisional orders to ensure the continuity of public services, such as license renewals, while internal disputes within professional organizations are resolved. However, such orders do not confer final authority or resolve the underlying internal conflict.
- Judicial
Review and Finality of Decisions
The judiciary retains the power to review the legality of actions taken by government agencies, especially when such actions affect the rights and obligations of individuals or organizations. However, once the issue becomes moot, any further judicial action may be unnecessary, as the court's decision would no longer serve a practical purpose. - Intra-Corporate
Disputes
In cases involving disputes within private organizations like PSME, the intra-corporate dispute resolution mechanisms, such as those governed by the Corporation Code of the Philippines, take precedence. Courts dealing with such disputes focus on internal procedures and governance issues specific to the organization rather than government regulations.
Case Classification:
This case falls under Remedial Law
From <https://chatgpt.com/c/66f0166a-4290-800a-be34-64e4429d56a1>
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🎓 In today’s jurisprudence
review, we discuss a landmark Remedial Law case that explores mootness,
judicial review, and the limits of administrative power. This
video aims to help law students, bar examinees, and legal
professionals recall key doctrines and appreciate their practical
application.
📚 The case is:
Professional Regulation Commission vs. Philippine Society
of Mechanical Engineers (PSME)
G.R. No. 254282 | September 14, 2021
👥 Parties Involved:
- Petitioner:
Professional Regulation Commission (PRC)
- Respondent:
Philippine Society of Mechanical Engineers (PSME), represented by Engr.
Murry F. Demdam
📝 Nature of the Case:
Remedial Law – Petition for Review on Certiorari concerning
the mootness of a petition for nullity of a PRC Office Order amid an
intra-corporate dispute over leadership within a professional organization.
🔍 Brief Summary:
Engr. Leandro Conti and Engr. Murry Demdam both claimed
presidency of PSME for 2016. The PRC recognized Conti through Office Order No.
2016-56. However, a lower court later declared Conti’s election void. The
Supreme Court ruled the case moot as the controversy had lost its
practical significance.
💭 Should government
agencies intervene in private organizational disputes if it helps maintain
essential public services? Let us know in the comments and don’t forget to like
and subscribe!
📌 10 Important
Doctrines from the Case:
- Doctrine
of Mootness
A case is moot when it no longer presents a justiciable controversy. Courts refrain from resolving cases with no practical legal effect. (See p. 38-41, Decision) - Judicial
Exceptions to Mootness
Courts may still rule on moot cases when public interest or constitutional issues are at stake. (p. 39) - Limits
of Administrative Power
PRC cannot decide internal disputes of private organizations unless tied directly to its regulatory functions. (p. 56-57) - Intra-Corporate
Disputes Governed by Civil Code
Internal elections and board conflicts must be resolved via intra-corporate remedies under the Corporation Code. (p. 55) - No
Res Judicata Without Identity of Parties and Issues
For res judicata to apply, parties, issues, and reliefs must be identical. Not the case here. (p. 58-61) - Provisional
Nature of PRC Orders
PRC’s recognition of Conti was not final and was subject to judicial outcomes. (p. 56; PRC Letter Feb 5, 2016) - Public
Service Must Continue Despite Internal Conflicts
PRC issued Order 2016-56 to ensure uninterrupted processing of license renewals amid the dispute. (p. 42) - Judicial
Economy and Redundancy
The Court will not resolve issues when no substantial relief can be granted. (p. 41) - Superseding
Events Can Nullify Relief Sought
When a trial court decision renders a dispute irrelevant, any pending related actions become moot. (p. 40) - Case
Law Reference: So v. Tacla Jr.
Established the four exceptions to mootness doctrine—public interest, constitutional principles, and likelihood of repetition. (citing p. 37)
⚖️ DISCLAIMER:
This content is for educational purposes only and does not
guarantee legal accuracy. It was created using premium Artificial Intelligence
and expert legal curation. Always consult official court decisions and legal
professionals for guidance.
📌 FREQUENTLY ASKED
QUESTIONS:
- Can
the PRC declare who the legitimate president of a professional
organization is?
No. It can only provisionally recognize officers for regulatory functions, but not decide intra-corporate disputes. - Why
did the Supreme Court dismiss the case?
The Court declared the case moot because the lower court had already voided Conti’s election. - Was
res judicata applicable in this case?
No. There was no identity of parties, causes of action, or reliefs sought in the two cases. - What
is the significance of mootness in legal proceedings?
It prevents courts from issuing rulings that no longer have practical or enforceable consequences. - Can
a PRC Order be challenged in court?
Yes, especially if it oversteps its legal authority or affects substantive rights.
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📖 Case Title:
Professional Regulation Commission v. PSME, G.R. No.
254282, September 14, 2021
From <https://chatgpt.com/c/66f0166a-4290-800a-be34-64e4429d56a1>
🎓 LAW PROFESSOR
INTRODUCTION TO THE QUIZZER
Welcome, future attorneys! This short quizzer is based on a 2021
Supreme Court decision that dives deep into Remedial Law,
particularly the doctrine of mootness, and the scope of authority of
administrative agencies. This is ideal for law students, bar reviewees,
and practicing lawyers sharpening their understanding of procedural
doctrines.
📌 Case Title:
Professional Regulation Commission vs. Philippine Society
of Mechanical Engineers (PSME)
G.R. No. 254282 | Promulgated on September 14, 2021
👥 Parties:
- Petitioner:
Professional Regulation Commission (PRC)
- Respondent:
Philippine Society of Mechanical Engineers (PSME), represented by Engr.
Murry F. Demdam
📝 Nature of the Case:
This is a Remedial Law case involving a petition for
review on certiorari seeking to nullify a Court of Appeals decision that
reinstated a nullity case filed against a PRC Office Order. The core legal
issue revolves around mootness—whether the petition to annul the PRC’s
recognition of a disputed PSME president remained justiciable after another
court had already voided said election.
🏛️ Supreme Court
Decision Summary:
The Court ruled the case moot, holding that the lower
court's prior decision voiding the disputed election had already resolved the
core controversy. Hence, the continuation of the nullity case served no legal
or practical purpose.
📌 Stay until the end of
this quiz—Answer Key will be provided at the conclusion of the video!
🔍 QUIZZER – Easy HOTS
(Higher Order Thinking Skills) Multiple Choice Questions:
1. What was the primary reason the Supreme Court
dismissed the nullity petition filed by PSME?
A. The PRC had revoked its Office Order
B. The PSME withdrew the case
C. The issue was rendered moot by a separate RTC decision
D. The Court lacked jurisdiction
2. Which of the following BEST describes the PRC’s
reason for issuing Office Order No. 2016-56?
A. To resolve the corporate dispute within PSME
B. To impose a new requirement for license renewal
C. To ensure continuity in professional services during
leadership conflict
D. To appoint Engr. Conti permanently as president
3. Which court originally dismissed the petition for
nullity on the ground of mootness?
A. Court of Appeals
B. Regional Trial Court – Branch 6
C. Regional Trial Court – Branch 24
D. The Supreme Court
4. Why did the Court of Appeals reverse the RTC’s
dismissal of the nullity case?
A. Because the RTC lacked evidence
B. Because res judicata clearly applied
C. Because there remained a justiciable issue on PRC’s
authority
D. Because the PRC did not follow due process
5. What triggered the intra-corporate dispute in
PSME?
A. Delay in license renewals
B. Conflict over the 2016 Board election results
C. Failure to file financial reports
D. Expulsion of a member from the organization
6. What principle limits courts from deciding cases
when there is no longer a live controversy?
A. Doctrine of standing
B. Doctrine of ripeness
C. Doctrine of judicial supremacy
D. Doctrine of mootness
7. In what way did the PRC clarify the temporary
nature of its Office Order?
A. By publishing an advisory
B. Through a press release
C. By letter stating recognition was without prejudice to
court ruling
D. In a Senate hearing
8. Which of the following statements is TRUE
regarding the decision of RTC Branch 24?
A. It declared Engr. Demdam as the 2016 PSME President
B. It upheld the November 25 election of Engr. Conti
C. It voided the election of the 2016 PSME National Officers
D. It ordered PRC to recognize both factions
9. What was the PRC’s interest in recognizing a PSME
president during the internal dispute?
A. To favor one faction politically
B. To ensure proper issuance of Certificates of Good
Standing
C. To avoid a lawsuit
D. To recommend a legislative amendment
10. What doctrine did the Supreme Court apply to
conclude the case had no practical effect?
A. Doctrine of exhaustion of administrative remedies
B. Doctrine of primary jurisdiction
C. Doctrine of mootness
D. Doctrine of judicial restraint
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