People of the Philippines vs Ventura
G.R. No. L-15079
Statement. —This is an appeal from the decision of the Court of First Instance of Rizal
finding Guillermo I. Ventura guilty of illegal practice of medicine under Section 770 in
connection with Section 2678 of the Revised Administrative Code, and sentencing
him, this being his second offense, to pay a fine in the sum of P500.00, with the
corresponding subsidiary imprisonment in case of insolvency and to pay costs.
Appellant, the accused, was charged with the above offense in an information which
alleged that in February, 1955, he did, .
"willfully, unlawfully and feloniously, and for compensation and reward,
practice medicine in the said City (Pasay) by treating and applying electrical
appliances to patients for the purpose of curing them with their ailments,
diseases, pains, and physical defects from which they are suffering and by
holding out himself to the public by means of signs, advertisements, and
other means, to be a Doctor of Medicine."
FACTS:
 "... in the year 1949, the accused herein, Guillermo I. Ventura, was convicted by
the court of first instance of Rizal of a 'similar offense' or illegal practice of
medicine in the municipality of Pasay, now Pasay City and sentenced to pay a
fine of P200.00 under the same legal provisions, or Section 770 in connection
with Section 2678 of the Revised Administrative Code.
 "... by reason of certain complaints the National Bureau of Investigation had
received from the President of the Philippine Federation of Private Medical
Practitioners and from the Chairman of the Board of Medical Examiners, the
National Bureau of Investigation on December 16, 1955, sent its morgue
attendant Jose Natayan to the clinic of the accused at No. 2454 M. de la Cruz
Street, Pasay City. Natayan was at that time suffering from pains in his back and
he asked the accused to see his sickness. The accused attended to Natayan;
wrote something on a piece of paper; and then he told him that he (Natayan)
'was sick of lumbago'. Thereupon, the accused asked Natayan to pay P5.00 and
then asked him to pay the amount to a lady employee in the clinic which Natayan
did. At the request of the accused, Natayan, then went around the other side of
the clinic where he was given an enema of hot water by a male attendant. Then
Natayan was asked to lie down on a table where his back was exposed to a big
bulb for around fifteen minutes and afterwards to a red colored bulb for another
ten minutes. Thereafter Natayan went back to the accused, who told him to
come back to his clinic for six consecutive days. After that Natayan went back on
the same day or December 16, 1955 to his office in the National Bureau of
Investigation.
 The following day, Natayan returned to the clinic of the accused with the
National Bureau of Investigation raiding party composed of two agents, two
attorneys and one photographer. After he was dropped by the National Bureau
of Investigation agents about seven meters away from the clinic of the accused,
Natayan proceeded to the office of the accused, who then and there told him
that another treatment would be applied to him and that he would pay P3.00.
After paying this amount and while Natayan was lying on a table about to be
given treatment the National Bureau of Investigation agents raided the place.
 The accused herein, Guillermo I. Ventura, is not a duly registered masseur or a
physician qualified to practice medicine.
ISSUES:
1. Whether or not the offense charged in the information had already prescribed?
2. Whether or not the laws involved are unconstitutional and void?
3. Whether or not that granting that the said laws are valid, the accused should
not have been prosecuted thereunder because he was not engaged in the
practice of medicine?
4. Whether or not the Congress, in passing House Bills Nos. 2405 and 357
recognized and believed in the efficacy of the drugless systems of healing and
although said bills were vetoed by the President of the Philippines and thereby
did not become regular statutes, they may be considered as concurrent
resolutions formally establishing the drugless system of healing as a separate and
distinct profession, not covered by Section 770 of the Medical Law?
5. Whether or not that the complainants and the Government are estopped from
prosecuting the accused under Section 770 because they were the ones who
induced him to practice drugless healing after his conviction in 1949
6. Whether or not the accused has an implied license to practice drugless healing
from the people of the Philippines and the Chairman of the Medical Board of
Examiners?
HELD:
1. NO.
 He argues that in view of the fact that he had begun the alleged practice of
medicine thirty-five years ago without the required license, the crime
charged in the information had already prescribed. The records reveal that
the accused began practicing his method of drugless healing 35 years ago.
This practice was first discovered by the authorities in 1949. He was
prosecuted and convicted therefor the same year.
 However, at about February, 1955, the President of the Philippine
Federation of Private Medical Practitioners, complained to the NBI that
appellant was advertising himself as capable of treating human ailments
without drugs.
 Upon investigation, appellant was found to be without certificate of
registration to practice such profession either from the Board of Medical
Examiners or from the Committee of Examiners of Masseurs. So, this
prosecution started in 1956. It is clear that the four-year period of
prescription of the offense charged should be computed from February,
1955 when the National Bureau of Investigation discovered appellant's
alleged illegal practice of Medicine.
2. No.
 It is appellant's theory that to require, of any person whose business is
merely to stimulate by mechanical means the nerves of the body, many
years of study in medical schools, taking up obstetrics, general surgery,
gynecology, bacteriology and many other sciences, is curtailment of the
exercise of one's calling, a violation of the constitutional principle that all
men have the right to life, liberty, and the pursuit of happiness and are
entitled to the equal protection of the law.
 It is furthermore theorized that inasmuch as drugless healing is not taught
in any of the medical schools prescribed, how could the members of the
Medical Board of Examiners pass on the competence of these drugless
healers? .
 It is settled by this Court in the case of People vs. Buenviaje who was
convicted of illegal practice of medicine for practicing chiropractor.2 It held:
There is very little force in this argument. The subjects in which an
examination is required relate to matters of which a thorough knowledge
seems necessary for the proper diagnosis of diseases of the human body and
it is within the police power of the State to require that persons who devote
themselves to the curing of human ills should possess such knowledge.
 In the instant case, we must again uphold these immutable concepts of the
police power of the State.
o Under this power, the State may prescribe such regulations as in its
judgment will secure or tend to secure the general welfare of the
people, to protect them against the consequences of ignorance and
incapacity as well as of deception and fraud.
o As one means to this end, it has been the practice of different States,
from time immemorial to exact in any pursuit, profession or trade, a
certain degree of skill and learning upon which the community may
confidently rely, their possession being generally ascertained in an
examination of parties by competent persons, or inferred from a
certificate to them in the form of a diploma or license from an
institution established for instruction on the subjects, scientific or
otherwise, with which such pursuits have to deal.3
3. No.
 Appellant claims that his act of stimulating the affected nerves of the
patients without use of any drug or medicine is not practice of medicine;
that "practice of medicine" is confined only to the systems taught by the
medical schools, namely, the regular, the homeopathic and the eclectic
schools or systems.
 Section 770 of the Revised Administrative Code in no uncertain terms covers
appellant's acts. The statutory definition as to what acts constitute illegal
practice of medicine its provided in said Section 770 includes the acts and
practices performed by appellant, By his own statements, he admitted to
have continuously diagnosed and treated more or less 500,000 instances of
different kinds of human ailments and to have prescribed remedies therefor.
4. No.
 As regards the contention that there are at least two concurrent resolutions
declaring formally that Congress has recognized the drugless methods of
healing, we need not elaborate further than to say that not until such
recognition is actually embodied in a statute, shall we extend consideration
of such method.
5. No.
 Appellant pleads that the lower court erred in not holding that the
complainants and the government are estopped from prosecuting him
because they were the ones who induced him to practice drugless healing
after his conviction in 1949. He tried to show that medical practitioners,
members of Congress, provincial governors, city mayors and municipal
board members wrote to him requesting his help for persons suffering from
all kinds of ailments; that municipal ordinances and resolutions were also
passed authorizing him not only to practice his method of healing but also
to put up clinics in some of municipalities; that he was even extended free
transportation facilities to work in the Central Luzon Sanitarium in Tala,
Caloocan, Rizal.
 Above plea cannot be sustained by this Court. The doctrine of estoppel does
not apply to the government.4 It is never stopped by mistakes or errors on
the part of its agents, even assuming without conceding that said
municipalities had encouraged appellant's practice. We cannot allow the
bargaining away of public health and safety for the semblance of benefit to
a few government officials, people or even municipalities.
6. No.
 Similarly, there is no such thing as implied license to practice drugless
healing by the mere fact that the Chairman of the Board of Medical
Examiners had permitted appellant to serve free in the Central Luzon
Sanitarium in Tala, Caloocan, Rizal, or that countless people persisted in
engaging his services. For one thing, these people might have contracted his
services on the mistaken notion that he was duly licensed to practice his
profession; for another, a repetition of illegal acts can never make them
legal.
 As additional argument, appellant urges acquittal under the new Medical
Act of 19595 wherein the practice of physiotherapy is recognized as a distinct
science. He claims coverage of said law on the ground that he practices
physiotherapy by massage through physical devices and upon the
recommendation of duly registered physicians.
  The above argument has no merit because there is strong evidence to the
effect that appellant alone diagnoses his patients' ailments and applies the
remedies therefor6 without written order or prescription by a registered
physician.

SC DECISION: Wherefore, the decision appealed from is hereby affirmed in all parts
and respects. Costs against appellant
DECS vs San Diego
G.R. No. 89572
The issue before us is mediocrity. The question is whether a person who has thrice
failed the National Medical Admission Test (NMAT) is entitled to take it again. The
petitioner contends he may not, under its rule that- A student shall be allowed only
3 chances to take the NMAT. After 3 successive failures, a student shall not be
allowed to take the NMAT for the fourth time. The private respondent insists he can,
on constitutional grounds.
Facts: Private respondent is a graduate of the University of the East with a degree of
BS Zoology. The petitioner claims that he took the NMAT 3 times and flunked it as
many times. When he applied to take it again, the petitioner rejected his application
on the basis of the aforesaid rule. He then went to the RTC of Valenzuela to compel
his admission to the test.
In his original petition for mandamus, he first invoked his constitutional rights to
academic freedom and quality education. By agreement of the parties, the private
respondent was allowed to take the NMAT scheduled on April 16, 1989, subject to
the outcome of his petition. In an amended petition filed with leave of court, he
squarely challenged the constitutionality of MECS Order No. 12, Series of 1972,
containing the above-cited rule. The additional grounds raised were due process and
equal protection.
Issue: Whether or not there was a violation of the Constitution on academic
freedom, due process and equal protection.
Held: No. The court upheld the constitutionality of the NMAT as a measure intended
to limit the admission to medical schools only to those who have initially proved their
competence and preparation for a medical education.
Ratio:
While every person is entitled to aspire to be a doctor, he does not have a
constitutional right to be a doctor. This is true of any other calling in which the public
interest is involved; and the closer the link, the longer the bridge to one's ambition.
The State has the responsibility to harness its human resources and to see to it that
they are not dissipated or, no less worse, not used at all. These resources must be
applied in a manner that will best promote the common good while also giving the
individual a sense of satisfaction.
The Court feels that it is not enough to simply invoke the right to quality education
as a guarantee of the Constitution: one must show that he is entitled to it because of
his preparation and promise. The private respondent has failed the NMAT five
times. While his persistence is noteworthy, to say the least, it is certainly misplaced,
like a hopeless love. No depreciation is intended or made against the private
respondent. It is stressed that a person who does not qualify in the NMAT is not an
absolute incompetent unfit for any work or occupation. The only inference is that he
is a probably better, not for the medical profession, but for another calling that has
not excited his interest. In the former, he may be a bungler or at least lackluster; in
the latter, he is more likely to succeed and may even be outstanding. It is for the
appropriate calling that he is entitled to quality education for the full harnessing of
his potentials and the sharpening of his latent talents toward what may even be a
brilliant future. We cannot have a society of square pegs in round holes, of dentists
who should never have left the farm and engineers who should have studied banking
and teachers who could be better as merchants. It is time indeed that the State took
decisive steps to regulate and enrich our system of education by directing the student
to the course for which he is best suited as determined by initial tests and
evaluations. Otherwise, we may be "swamped with mediocrity," in the words of
Justice Holmes, not because we are lacking in intelligence but because we are a
nation of misfits.
Crisostomo vs SEC 1. No. The investments in UDMC of Doctors Yamada and Enatsu do not violate
G.R. Nos. 89095 and 89555 the Constitutional prohibition against foreigners practicing a profession in
the Philippines (Sec 14, Art XII, 1987 Constitution) for they do not practice
FACTS: their profession (medicine) in the Philippines, neither have they applied for
Sixto Crisostomo, Felipe Crisostomo, Juanito Crisostomo et al were the original a license to do so. They only own shares of stock in a corporation that
stockholders of the United Doctors Medical Center (UDMC), which was organized in operates a hospital. No law limits the sale of hospital shares of stock to
1968 with authorized capital stock of P1 million (later increased to P15 million in doctors only. The ownership of such shares does not amount to engaging
1972). They owned 40% of the outstanding stock while the majority belonged to the (illegally) in the practice of medicine, or, nursing. If it were otherwise, the
members of the United Medical Staff Association (UMSA) petitioner's stockholding in UDMC would also be illegal.
1. Despite their minority status, the Crisostomo group has managed UDMC 2. Yes. All three actions he filed raise the same issues that he raised in the
from its inception with Juanito Crisostomo as president and petitioner Sixto different tribunals. There is forum-shopping whenever, as a result of an
Crisostomo as director and legal counsel adverse opinion in one forum, a party seeks a favorable opinion (other than
2. In 1988, UDMC defaulted in its obligation to pay P55 million to DBP. In the by appeal or certiorari) in another. The principle applies not only with
last quarter of 1987, UDMC’s assets and those of the Crisostomos which had respect to suits filed in the courts but also in connection with litigations
been given to DBP as collateral, faced foreclosure by the Asset Privatization commenced in the courts while an administrative proceeding is pending, as
Trust (APT), which had taken over UDMC’s loan. in this case, in order to defeat administrative processes and in anticipation
3. As such, UDMC, through Ricardo Alfonso and Juanito Crisostomo, persuaded of an unfavorable administrative ruling and a favorable court ruling.
the Yamadas and Enatsu (Shoji Yamada and Tomatada Enatsu are Japanese Forum-shopping makes the Crisostomo subject to disciplinary action and
doctors) to invest fresh capital in UDMC. The wife of Enatsu is a Filipina. They renders his petitions in the Supreme Court and in the Court of Appeals
invested P57 million in UDMC dismissible. He and his counsel are guilty of contempt. Crisosotmo is ordered
4. The investment was effected by means of a stock purchase agreement and by the Supreme Court to pay double the costs of the suit.
an amended memorandum of agreement whereby the private respondents
subscribed to 82.09% of the outstanding shares of UDMC. Both transactions
were authorized by the BOD and stockholders of UDMC, and approved by
BSP and SEC
5. The said capital not only saved the assets of UDMC from foreclosure but also
freed the Crisostomos group their individual and solidary liabilities as
sureties for the DBP loan
6. However, petitioner Sixto Crisostomo filed an SEC case against Juanito
Crisostomo, Yamada and Enatsu to stop the holding of the stockholder’s and
BOD meeting and to disqualify the Japanese investors from holding a
controlling interest in UDMC
7. Subsequently, petitioner filed a case with RTC Makati seeking a preliminary
injunction and identical reliefs prayed for by him in the SEC case.
8. Petitioner alleged that Yamada and Enatsu violated the Constitutional
prohibition against foreigners practicing a profession in the Philippines (Sec
14, Art XII 1987 Constitution

ISSUE:
1. WON the investments made by Yamada and Enatsu constitute illegal
practice of profession by foreigners in the Philippines
2. WON Crisostomo is guilty of forum shopping
HELD:
Tablarin vs Gutierrez
G.R. No. 78164
Facts:
The petitioners sought admission into colleges or schools of medicine for the school
year 1987-1988. However, the petitioners either did not take or did not successfully
take the National Medical Admission Test (NMAT) required by the Board of Medical
Education, one of the public respondents, and administered by the private
respondent, the Center for Educational Measurement (CEM).
On 5 March 1987, the petitioners filed with the Regional Trial Court,
National Capital Judicial Region, a Petition for Declaratory Judgment and Prohibition
with a prayer for Temporary Restraining Order and Preliminary Injunction. 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
Section 5 (a) and (f) of Republic Act No. 2382, as amended, and MECS Order No. 52,
series of 1985, dated 23 August 1985 and from requiring 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. After hearing on the
petition for issuance of preliminary injunction, the trial court denied said petition.
The NMAT was conducted and administered as previously scheduled.
Issue:
Whether Section 5 (a) and (f) of Republic Act No. 2382, as amended, offend against
the constitutional principle which forbids the undue delegation of legislative power,
by failing to establish the necessary standard to be followed by the delegate, the
Board of Medical Education
Held:
The standards set for subordinate legislation in the exercise of rule making authority
by an administrative agency like the Board of Medical Education are necessarily
broad and highly abstract. The standard may be either expressed or implied. If the
former, the non-delegation objection is easily met. The standard though does not
have to be spelled out specifically. It could be implied from the policy and purpose of
the act considered as a whole. In the Reflector Law, clearly the legislative objective is
public safety.
In this case, the necessary standards are set forth in Section 1 of the 1959 Medical
Act: “the standardization and regulation of medical education” and in Section 5 (a)
and 7 of the same Act, the body of the statute itself, and that these considered
together are sufficient compliance with the requirements of the non-delegation
principle.
PRC vs de Guzman
G.R. No. 144681
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. 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 court’s judgment is rendered ordering the respondents
to allow the petitioners and intervenors to take the physician’s 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 (prescribes that a person who
aspires to practice medicine in the Philippines, must have “satisfactorily passed the
corresponding Board Examination) 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.
*satisfactorily- defined as “sufficient to meet a condition or obligation” or “capable
of dispelling doubt or ignorance”
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.
Board of Medicine vs Ota
G.R. No. 166097
FACTS:
 Yasuyuki Ota (respondent) is a Japanese national, married to a Filipina, who has
continuously resided in the Philippines for more than 10 years. He graduated
from Bicol Christian College of Medicine on April 21, 1991 with a degree of
Doctor of Medicine. After successfully completing a one-year post graduate
internship training at the Jose Reyes Memorial Medical Center, he filed an
application to take the medical board examinations in order to obtain a medical
license. He was required by the (PRC) to submit an affidavit of undertaking,
stating among others that should he successfully pass the same, he would not
practice medicine until he submits proof that reciprocity exists between Japan
and the Philippines in admitting foreigners into the practice of medicine.
 Respondent submitted a duly notarized English translation of the Medical
Practitioners Law of Japan duly authenticated by the Consul General of the
Philippine Embassy to Japan, Jesus I. Yabes; thus, he was allowed to take the
Medical Board Examinations in August 1992, which he subsequently passed.
 In spite of all these, the Board of Medicine (Board) of the PRC, in a letter dated
March 8, 1993, denied respondent's request for a license to practice medicine
in the Philippines on the ground that the Board “believes that no genuine
reciprocity can be found in the law of Japan as there is no Filipino or foreigner
who can possibly practice there.”
 Respondent then filed a Petition for Certiorari and Mandamus against the Board
before the RTC of Manila. RTC ruled for the Yasuki.
 The Board and the PRC (petitioners) appealed the case to the CA, stating that
while respondent submitted documents showing that foreigners are allowed to
practice medicine in Japan, it was not shown that the conditions for the practice
of medicine there are practical and attainable by a foreign applicant, hence,
reciprocity was not established; also, the power of the PRC and the Board to
regulate and control the practice of medicine is discretionary and not ministerial,
hence, not compellable by a writ of mandamus.
 The CA denied the appeal and affirmed the ruling of the RTC.
ISSUES:
WHETHER THE COURT OF APPEALS COMMITTED A REVERSIBLE ERROR IN FINDING
THAT RESPONDENT HAD ESTABLISHED THE EXISTENCE OF RECIPROCITY IN THE
PRACTICE OF MEDICINE BETWEEN THE PHILIPPINES AND JAPAN.
 RULING: attainable by Filipinos. Neither is it stated that it must first be proven that a
The Court denies the petition for lack of merit. Filipino has been granted license and allowed to practice his profession in said
There is no question that a license to practice medicine is a privilege or franchise country before a foreign applicant may be given license to practice in the
granted by the government. It is a right that is earned through years of education
Philippines.
and training, and which requires that one must first secure a license from the state
through professional board examinations.  It is enough that the laws in the foreign country permit a Filipino to get license
[T]he regulation of the practice of medicine in all its branches has long been and practice therein. Requiring respondent to prove first that a Filipino has
recognized as a reasonable method of protecting the health and safety of the public. already been granted license and is actually practicing therein unduly expands
That the power to regulate and control the practice of medicine includes the power the requirements provided for under R.A. No. 2382 and P.D. No. 223.
to regulate admission to the ranks of those authorized to practice medicine, is also  Indeed, to be granted the privilege to practice medicine, the applicant must show
well recognized. Thus, legislation and administrative regulations requiring those
that he possesses all the qualifications and none of the disqualifications. It must
who wish to practice medicine first to take and pass medical board examinations
also appear that he has fully complied with all the conditions and requirements
have long ago been recognized as valid exercises of governmental power.
As required by the said laws, respondent submitted a copy of the Medical imposed by the law and the licensing authority.
Practitioners Law of Japan, duly authenticated by the Consul General of the Embassy  In this case, there is no doubt as to the competence and qualifications of
of the Philippines in Japan, which provides in Articles 2 and 11, thus: respondent. He finished his medical degree from Bicol Christian College of
Article 2. Anyone who wants to be medical practitioner must pass the national Medicine. He completed a one-year post graduate internship training at the Jose
examination for medical practitioner and get license from the Minister of Health and Reyes Memorial Medical Center, a government hospital. Then he passed the
Welfare.
Medical Board Examinations which was given on August 8, 1992 with a general
xxx
Article 11. No one can take the National Medical Examination except persons who average of 81.83, with scores higher than 80 in 9 of the 12 subjects.
conform to one of the following items:
1. Persons who finished regular medical courses at a university based on the School
Education Laws (December 26, 1947) and graduated from said university.
2. Persons who passed the preparatory test for the National Medical Examination
and practiced clinics and public sanitation more than one year after passing the said
test.
3. Persons who graduated from a foreign medical school or acquired medical
practitioner license in a foreign country, and also are recognized to have the same or
more academic ability and techniques as persons stated in item 1 and item 2 of this
article.

R.A. No. 2382, which provides who may be candidates for the medical board
examinations, merely requires a foreign citizen to submit competent and conclusive
documentary evidence, confirmed by the Department of Foreign Affairs (DFA),
showing that his country’s existing laws permit citizens of the Philippines to practice
medicine under the same rules and regulations governing citizens thereof.
PRC is authorized to prescribe additional requirements or grant certain privileges to
foreigners seeking registration in the Philippines if the same privileges are granted to
or some additional requirements are required of citizens of the Philippines in
acquiring the same certificates in his country.
 Nowhere in said statutes is it stated that the foreign applicant must show that
the conditions for the practice of medicine in said country are practical and