The Professional Regulation Commission (PRC) issued, amid the pandemic, a moratorium on the CPD credits requirement for renewal of professional license until December 31, 2021. This initiative of the Commission is supposed to give relief to the 43 regulated professions during this equally financially challenging time. However, certificate of good standing (COGS) from the respective accredited professional organization (APO) as a requirement still stands for 16 of said regulated professions.
There lies an irony when a requirement mandated by law passed by Congress, such as the CPD credits, is dispensed with and the one without legal basis, such as the (COGS), is not. The COGS as a requirement is not only a useless burden for the affected professionals but also illegal, per se, and therefore must be abolished perpetually on the following grounds:
1. No law or any provision of law passed by Congress mandating it.
2. Violative of the equal protection clause of the 1987 Constitution as it only applies to 16 of the 43 regulated professions.
3. It is an illegal exaction. Any amount paid by the professional to secure a COGS is in effect a levy for the practice of profession for the benefit of the respective APO, a private entity, and not for any public use or purpose.
4. The practice of profession is a privilege granted by the State to qualified individuals and, as such, only the State may regulate the same. The COGS as a requirement is in effect granting the APO the power determine for itself who may or may not practice such profession, a regulatory act.
