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Tablarin V Guttierez

The document discusses a case regarding a requirement to pass the National Medical Admission Test (NMAT) as a condition for admission to medical schools in the Philippines. The court held that requiring certain minimum scores on the NMAT is constitutional and a valid use of police power, as it reasonably relates to securing public health and safety by helping to ensure the quality of medical education and selection of qualified applicants.
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0% found this document useful (0 votes)
56 views2 pages

Tablarin V Guttierez

The document discusses a case regarding a requirement to pass the National Medical Admission Test (NMAT) as a condition for admission to medical schools in the Philippines. The court held that requiring certain minimum scores on the NMAT is constitutional and a valid use of police power, as it reasonably relates to securing public health and safety by helping to ensure the quality of medical education and selection of qualified applicants.
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Tablarin V.

Gutierrez 152 SCRA 730

Facts: The petitioners sought to enjoin the Secretary of Education, Culture and
Sports, the Board of Medical Education and the Center for Educational
Measurement from enforcing a requirement the taking and passing of the
NMAT as a condition for securing certificates of eligibility for admission, from
proceeding with accepting applications for taking the NMAT and from
administering the NMAT as scheduled on 26 April 1987 and in the future. The
trial court denied said petition and the NMAT was conducted and administered
as scheduled.
The NMAT, an aptitude test, is considered as an instrument toward upgrading
the selection of applicants for admission into the medical schools and its
calculated to improve the quality of medical education in the country. The
cutoff score for the successful applicants, based on the scores on the NMAT,
shall be determined every year by the Board of Medical Education after
consultation with the Association of Philippine Medical Colleges. The NMAT
rating of each applicant, together with the other admission requirements as
presently called for under existing rules, shall serve as a basis for the issuance
of the prescribed certificate of eligibility for admission into the medical colleges.

Issue: Whether or not Section 5 (a) and (f) of Republic Act No. 2382, as
amended, and MECS Order No. 52, s. 1985 are constitutional.

Held: Yes. We conclude that prescribing the NMAT and requiring certain
minimum scores therein as a condition for admission to medical schools in the
Philippines, do not constitute an unconstitutional imposition.
The police power, it is commonplace learning, is the pervasive and
non-waivable power and authority of the sovereign to secure and promote all
the important interests and needs — in a word, the public order — of the
general community. An important component of that public order is the health
and physical safety and well being of the population, the securing of which no
one can deny is a legitimate objective of governmental effort and regulation.
Perhaps the only issue that needs some consideration is whether there is
some reasonable relation between the prescribing of passing the NMAT as a
condition for admission to medical school on the one hand, and the securing of
the health and safety of the general community, on the other hand. This
question is perhaps most usefully approached by recalling that the regulation
of the practice of medicine in all its branches has long been recognized as a
reasonable method of protecting the health and safety of the public.

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