[T]he regulation of the practice of medicine in all its PRC is authorized to prescribe additional requirements or
branches has long been recognized as a reasonable grant certain privileges to foreigners seeking registration
method of protecting the health and safety of the public. in the Philippines if the same privileges are granted to or
That the power to regulate and control the practice of some additional requirements are required of citizens of
medicine includes the power to regulate admission to the the Philippines in acquiring the same certificates in his
ranks of those authorized to practice medicine, is also well country.
recognized. Thus, legislation and administrative
Nowhere in said statutes is it stated that the
regulations requiring those who wish to practice medicine
foreign applicant must show that the conditions for the
first to take and pass medical board examinations have
practice of medicine in said country are practical and
long ago been recognized as valid exercises of
attainable by Filipinos. Neither is it stated that it must
governmental power.
first be proven that a Filipino has been granted license and
As required by the said laws, respondent submitted a copy allowed to practice his profession in said country before a
of the Medical Practitioners Law of Japan, duly foreign applicant may be given license to practice in the
authenticated by the Consul General of the Embassy of Philippines.
the Philippines in Japan, which provides in Articles 2 and
It is enough that the laws in the foreign country
11, thus:
permit a Filipino to get license and practice therein.
Article 2. Anyone who wants to be medical practitioner Requiring respondent to prove first that a Filipino has
must pass the national examination for medical already been granted license and is actually practicing
practitioner and get license from the Minister of Health therein unduly expands the requirements provided for
and Welfare. under R.A. No. 2382 and P.D. No. 223.
ISSUES:
19. MACIAS VS. MACIAS
1. WON respondent Lucas was denied due process when
the CSC found him guilty of grave misconduct on a 20. OFFICE OF THE COURT
charge of simple misconduct. ADMINISTRATOR VS. INDAR
2. WON the act complained of constitutes grave
misconduct.
21. INGARAHAM VS. WRIGHT
RELEVANT FACTS:
HELD:
James Ingraham was a junior high student in a Florida
1. The SC sustained the ruling of the CA that the basic public school. After failing to respond quickly to a
requirement of due process is that a person must be duly teachers instructions, Ingraham was brought to Principal
informed of the charges against him, and that a person Willie Wrights office where he refused to admit the
cannot be convicted of a crime which he was not charged. infraction. Ingraham was then subjected to corporal
Administrative proceedings are not exempt from basic punishment by Principal Wright, with the help of the
and fundamental procedural principles, such as the right Assistant Principal and his personal assistant. According
to due process in investigations and hearings. 2. Under the to the record, Ingrahams spanking was particularly harsh
circumstances, the act of the respondent is not constitutive as he was subjected to twenty separate strokes from the
of grave misconduct, in the absence of proof that wooden paddle. Ingrahams doctors ordered him to
respondent was maliciously motivated. It has also been remain out of school to recover from injuries sustained
noted that the respondent has been in the service for 20 during his paddling. Ingraham and another student
years and this is his first offense. brought suit alleging that Florida law allowing corporal
punishment violated the Eighth Amendment, violated
their due process rights, and sought damages in addition
to declaratory and injunctive relief. The district Court
15. CSC VS. LEDESMA granted Wrights motion to dismiss and the Court of
Appeals affirmed.
16. ANONYMOUS VS. RADAM
ISSUE:
Does the Eighth Amendment bar corporal punishment in
17. PEFIANCO VS. MORAL
public schools? Does due process require notice to parents
FACTS: before corporal punishment is imposed?
HOLDING: Petitioners Diosdado Guzman, Ulysses Urbiztondo and
Ariel Ramacula, students of respondent National
No, the Eighth Amendment has no application to corporal
University, have come to this Court to seek relief from
punishment in public schools. No, notice is not required
what they describe as their school's "continued and
before administering punishing as the Florida statutory
persistent refusal to allow them to enrol." In their petition
scheme contains adequate safeguards to prevent wrongful
"for extraordinary legal and equitable remedies with
punishment, and affords adequate remedies in the event a
prayer for preliminary mandatory injunction" dated
student is deprived of his rights.
August 7, 1984, they alleged that they were denied due
REASONING: process due to the fact that they were active participants
in peaceful mass actions within the premises of the
Justice Powell delivered the opinion of the Court. First, University.
the majority noted that the Eighth Amendment
historically applied to those convicted of crimes rather The respondents on the other hand claimed that the
than to the disciplining of school children. Justice Powell petitioners failure to enroll for the first semester of the
explained that there was no basis for extending the Eighth school year 1984-1985 is due to their own fault and not
Amendment beyond that historical context, particularly as because of their alleged exercise of their constitutional
applied to schools that are already carefully monitored by and human rights. That as regards to Guzman, his
local communities. Furthermore, aggrieved students and academic showing was poor due to his activities in
parents can seek criminal and civil remedies in the event leading boycotts of classes. That Guzman is facing
punishments exceed what is necessary to enforce rules criminal charges for malicious mischief before the
and impose discipline within the school environment. Metropolitan Trial Court of Manila in connection with the
Next, the Court turned to the Due Process issue, destruction of properties of respondent University. The
explaining that both physical restraint and infliction of petitioners have failures in their records, and are not of
pain are within the historical meaning of liberty interest good scholastic standing.
protected by guarantees of due process of law. Children
ISSUE:
obviously have a strong and legitimate interest in
avoiding unwarranted punishments or being WON the petitioners were denied due process.
unnecessarily deprived of their liberty. However, the
Court here concluded Florida law already contained HELD:
adequate protections, with teachers and principals alike Immediately apparent from a reading of respondents'
required to exercise prudence in applying punishments, comment and memorandum is the fact that they had never
subject to the watchful eye of the community and the conducted proceedings of any sort to determine whether
possibility of subsequent civil or criminal liability for or not petitioners-students had indeed led or participated
wrongful behavior. The Court saw no need to add pre- "in activities within the university premises, conducted
punishment notifications, as school discipline has always without prior permit from school authorities, that
been handled without the need for prior notification or disturbed or disrupted classes therein" 3 or perpetrated
hearings. Finally, the Court explained that imposing acts of "vandalism, coercion and intimidation, slander,
additional requirements on schools seeking to impose noise barrage and other acts showing disdain for and
punishments would intrude state authority to regulate defiance of University authority." 4 Parenthetically, the
schools. Justice Powell pointed out that additional pendency of a civil case for damages and a criminal case
safeguards may well require schools to abandon certain for malicious mischief against petitioner Guzman, cannot,
modes of punishment, and any small benefit from adding without more, furnish sufficient warrant for his expulsion
constitutional remedies to already existing tort and or debarment from re-enrollment. Also apparent is the
criminal remedies were small compared to the important omission of respondents to cite this Court to any duly
interests of schools protecting their educational published rule of theirs by which students may be
environments. expelled or refused re-enrollment for poor scholastic
standing.