Supreme Court. INQUIRER FILE PHOTO
MANILA, Philippines — Only registered and licensed architects may sign architectural documents, the Supreme Court clarified in a recent ruling.
In a decision penned by Senior Associate Justice Marvic Leonen, the high court’s Second Division resolved the conflicting provisions of Republic Act No. 544, or the Civil Engineering Law, and RA 9266, or the Architecture Act of 2002.
The Civil Engineering Law grants authority to civil engineers to prepare, sign and seal various plans, including architectural documents. The Architecture Act, on the other hand, states that “[a]ll architectural plans, designs, specifications, drawings, and architectural documents relative to the construction of a building shall bear the seal and signature only of” a registered and licensed architect.
“The Court, finding the foregoing provisions ‘irreconcilable,’ ruled that the Architecture Act impliedly repealed the Civil Engineering Law insofar as it permits civil engineers to prepare, sign and seal architectural documents,” the high court said in a statement.
“The repeal of a statute is a matter of legislative intent … the language of [the Architecture Act] reveals an intention on the part of the legislature to provide for a limitation on the civil engineers’ authority to prepare, sign and seal documents relating to building construction,” the court said.
The case stemmed from the petition for declaratory relief filed before a regional trial court (RTC) by Leo Cleto Gamolo and the Philippine Institute of Civil Engineers Inc. seeking to declare as void Sections 302(3) and 302(4) of the National Building Code’s revised implementing rules and regulations.
The respondents also asked the RTC that civil engineers be authorized to prepare, sign and seal the documents listed in Section 302(4) of the revised implementing rules and regulations.