Fundamental Principles and State Policies: Rearing of the
Youth
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.
Rationale:
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.