Scrap CoGS Rule for Criminologists' License Renewal – It’s Unfair and Unnecessary

Recent signers:
Eric Moises and 19 others have signed recently.

The Issue

Licensed criminologists in the Philippines are currently required to obtain a Certificate of Good Standing (CoGS) from the Philippine Criminologists Association of the Philippines (PCAP) as a prerequisite for renewing their PRC licenses. This requirement imposes a significant financial burden, as professionals are obligated to pay more than ₱2,000 in assorted fees before the CoGS is issued — a certificate that bears no direct relevance to one’s professional competence or qualifications for public service.

This policy applies even to criminologists actively serving in government institutions such as the PNP, BFP, BJMP, and other law enforcement agencies, where personnel are already held to high standards of integrity, undergo appropriate training, and are subject to strict codes of conduct.

In this context, the CoGS serves no practical regulatory purpose and functions merely as a redundant and unjust obligation, especially for professionals already under constant institutional oversight.

In light of these concerns, we, licensed criminologists across the country, respectfully call on the Philippine Criminologists Association of the Philippines (PCAP) and Professional Regulation Commission (PRC) to immediately revoke the mandatory CoGS requirement for license renewal.

 This requirement is:

🔴 Not required by law. The Criminology Profession Act of 2018 (Republic Act No. 11131) does not provide that membership in the Philippine Criminologists Association of the Philippines, Inc. (PCAP) or the acquisition of a CoGS is a requirement for either licensure or license renewal. The imposition of such a requirement, based merely on administrative issuances or resolutions, lacks legislative basis and therefore constitutes ultra vires regulation.

Nowhere in RA 11131 does it say:

That membership in PCAP is required, or
That CoGS is a condition for licensure or renewal.

🔴 Unconstitutional. Under Article III, Section 8 of the 1987 Constitution, the State shall not abridge the right of the people to form or refrain from forming associations. Compelling licensed professionals to join a private organization as a precondition to license renewal amounts to forced association, in violation of this constitutional right.

As held in jurisprudence such as Reyes v. RTC, G.R. No. 104942, June 24, 1993, the freedom to associate necessarily includes the freedom not to associate.

Therefore, requiring a CoGS has no express legal foundation under this law.

🔴 Applied unfairly. Under PRC Resolution No. 1957 (s. 2025), the requirement to submit a CoGS has been removed for most regulated professions. However, criminologists remain among the few professions still burdened by this requirement. This unequal application of policy results in inequitable treatment and raises serious concerns over fairness and consistency in the regulation of licensed professionals.

🔴 Redundant and financially abusive. Many licensed criminologists are employed in law enforcement agencies, where they undergo rigorous background checks and administrative evaluations. Requiring a CoGS in this context is redundant and unnecessary.

Furthermore, the financial burden of obtaining CoGS is excessive:

Membership Fee (3 years): ₱500.00
Annual Dues (3 years): ₱900.00
ID Card: ₱200.00
CoGS Fee: ₱1,000.00
Mailing Fee: ₱200.00
➡️ Total: ₱2,800.00

This imposes an unreasonable cost on professionals who are already compliant with government service and qualification standards.

We demand:

✅ Immediately repeal the requirement for a Certificate of Good Standing (CoGS) for the renewal of criminologist licenses;
✅ Adopt uniform and merit-based standards for all regulated professions under PRC’s jurisdiction;
✅ Uphold the constitutional and statutory rights of licensed criminologists and promote accessibility, fairness, and legality in professional regulation.

There is no legal basis under RA 11131, RA 8981, or any statute that mandates licensed criminologists to obtain a Certificate of Good Standing (CoGS) from PCAP before renewing their license. Any such requirement is imposed only through administrative issuances, which are inferior to the law and potentially unconstitutional, as they compel membership in a private organization without legal justification.

Additionally, because the CoGS is made a mandatory requirement before license renewal, many criminologists feel they are left with no choice but to comply, even if they disagree with the policy — simply to continue practicing their profession. Others, unable or unwilling to pay the excessive fees, have opted not to renew their licenses at all, despite being fully qualified. This results in unjust exclusion and professional disruption for many, solely due to a financially and legally questionable policy.

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Recent signers:
Eric Moises and 19 others have signed recently.

The Issue

Licensed criminologists in the Philippines are currently required to obtain a Certificate of Good Standing (CoGS) from the Philippine Criminologists Association of the Philippines (PCAP) as a prerequisite for renewing their PRC licenses. This requirement imposes a significant financial burden, as professionals are obligated to pay more than ₱2,000 in assorted fees before the CoGS is issued — a certificate that bears no direct relevance to one’s professional competence or qualifications for public service.

This policy applies even to criminologists actively serving in government institutions such as the PNP, BFP, BJMP, and other law enforcement agencies, where personnel are already held to high standards of integrity, undergo appropriate training, and are subject to strict codes of conduct.

In this context, the CoGS serves no practical regulatory purpose and functions merely as a redundant and unjust obligation, especially for professionals already under constant institutional oversight.

In light of these concerns, we, licensed criminologists across the country, respectfully call on the Philippine Criminologists Association of the Philippines (PCAP) and Professional Regulation Commission (PRC) to immediately revoke the mandatory CoGS requirement for license renewal.

 This requirement is:

🔴 Not required by law. The Criminology Profession Act of 2018 (Republic Act No. 11131) does not provide that membership in the Philippine Criminologists Association of the Philippines, Inc. (PCAP) or the acquisition of a CoGS is a requirement for either licensure or license renewal. The imposition of such a requirement, based merely on administrative issuances or resolutions, lacks legislative basis and therefore constitutes ultra vires regulation.

Nowhere in RA 11131 does it say:

That membership in PCAP is required, or
That CoGS is a condition for licensure or renewal.

🔴 Unconstitutional. Under Article III, Section 8 of the 1987 Constitution, the State shall not abridge the right of the people to form or refrain from forming associations. Compelling licensed professionals to join a private organization as a precondition to license renewal amounts to forced association, in violation of this constitutional right.

As held in jurisprudence such as Reyes v. RTC, G.R. No. 104942, June 24, 1993, the freedom to associate necessarily includes the freedom not to associate.

Therefore, requiring a CoGS has no express legal foundation under this law.

🔴 Applied unfairly. Under PRC Resolution No. 1957 (s. 2025), the requirement to submit a CoGS has been removed for most regulated professions. However, criminologists remain among the few professions still burdened by this requirement. This unequal application of policy results in inequitable treatment and raises serious concerns over fairness and consistency in the regulation of licensed professionals.

🔴 Redundant and financially abusive. Many licensed criminologists are employed in law enforcement agencies, where they undergo rigorous background checks and administrative evaluations. Requiring a CoGS in this context is redundant and unnecessary.

Furthermore, the financial burden of obtaining CoGS is excessive:

Membership Fee (3 years): ₱500.00
Annual Dues (3 years): ₱900.00
ID Card: ₱200.00
CoGS Fee: ₱1,000.00
Mailing Fee: ₱200.00
➡️ Total: ₱2,800.00

This imposes an unreasonable cost on professionals who are already compliant with government service and qualification standards.

We demand:

✅ Immediately repeal the requirement for a Certificate of Good Standing (CoGS) for the renewal of criminologist licenses;
✅ Adopt uniform and merit-based standards for all regulated professions under PRC’s jurisdiction;
✅ Uphold the constitutional and statutory rights of licensed criminologists and promote accessibility, fairness, and legality in professional regulation.

There is no legal basis under RA 11131, RA 8981, or any statute that mandates licensed criminologists to obtain a Certificate of Good Standing (CoGS) from PCAP before renewing their license. Any such requirement is imposed only through administrative issuances, which are inferior to the law and potentially unconstitutional, as they compel membership in a private organization without legal justification.

Additionally, because the CoGS is made a mandatory requirement before license renewal, many criminologists feel they are left with no choice but to comply, even if they disagree with the policy — simply to continue practicing their profession. Others, unable or unwilling to pay the excessive fees, have opted not to renew their licenses at all, despite being fully qualified. This results in unjust exclusion and professional disruption for many, solely due to a financially and legally questionable policy.

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