Can Schools Block Students from Taking Board Exams to Keep a “100% Passing Rate”? (Philippine Law)

Executive summary

No. In the Philippines, once a student has completed all academic requirements and graduated from a CHED-recognized program, a school has no lawful discretion to prevent that graduate from applying for a Professional Regulation Commission (PRC) licensure examination merely to preserve institutional “100% passing” optics. A school’s role is ministerial: to truthfully certify academic credentials (e.g., issue an official transcript and certification of graduation) so the graduate can apply to the PRC. Refusing or delaying the release of required records for image-management reasons can expose the school to administrative sanctions, civil liability for abuse of rights, and, in egregious cases, criminal liability (e.g., grave coercion).

Why schools cannot “screen out” graduates for PRC exams

1) PRC—not schools—controls admission to licensure exams

Under the Professional Regulatory Laws and the PRC Modernization Act (RA 8981), eligibility for licensure exams is governed by statute and PRC regulations. Schools certify facts (that you finished a qualifying degree from a recognized program); they do not have licensing power. A school cannot add extra, non-legal hurdles (like an internal “board exam clearance based on predicted pass rate”) to determine who may sit the exam.

2) Duty to release academic records

The Education Act of 1982 (BP 232), the CHED charter (RA 7722), and the CHED Manual of Regulations for Private Higher Education recognize students’ rights to records, grades, and issuance of transcripts within reasonable time upon completion and payment of lawful fees. Once you’ve graduated and settled legitimate obligations, the registrar’s ministerial duty is to issue:

Official Transcript of Records (OTR/TOR) with authenticating remarks as required by PRC;
Certification/Diploma/Certificate of Graduation;
Related school forms the PRC prescribes for that profession.

Blocking or slow-walking these because the school fears lower pass rates is not a lawful ground.

3) “Abuse of rights” is actionable

Even where a private school has some discretion (e.g., processing queues, verification), it must exercise rights with justice and good faith (Civil Code, Arts. 19–21). A strategic refusal to issue records to suppress “risky” examinees can amount to:

Abuse of rights / tort (damages available);
Unfair/unreasonable practice subject to CHED administrative discipline;
Grave coercion (Revised Penal Code Art. 286) if the school uses intimidation to stop a lawful act (taking a licensure exam).

What schools may lawfully require (and what they may not)

Lawful grounds (narrow and fact-based)

Unpaid lawful charges directly tied to records release (e.g., official transcript fee, approved accountabilities). Note: Charges must be lawful, published, and reasonable; blanket “pay the donation” or extraneous fees are suspect.
Unresolved academic deficiency (e.g., a grade not yet finalized; a missing requirement).
Authenticity/verification steps typical for registrars (reasonable processing time; anti-fraud checks).
Pending final disciplinary case before graduation (due process required).

Unlawful or highly questionable grounds

“We’re preserving our 100% passing rate.”
“Only those the dean endorses may file with PRC.”
“You must achieve review-center mock test cutoff or we won’t issue your TOR.”
“Quota: we will certify only 30 takers this cycle.”
Conditioning release on unrelated payments or donations.
Retaliation for declining a school-affiliated review center.

Distinguishing two moments in time

A) Before graduation

Schools can set retention policies (GPA floors, remedial paths) if they’re lawful, published in the Student Handbook, and CHED-compliant. These govern who graduates. They cannot be invented retroactively to control who takes the PRC exam.

B) After graduation

Once a student graduates, the school’s job is to promptly certify the truth (you earned the degree). “Gatekeeping” who sits the PRC exam is ultra vires (beyond the school’s authority).

Practical roadmap if you are being blocked

Write a formal demand to the Registrar/Dean
- Cite your graduation date, the exact documents requested (TOR “for board exam,” Certification of Graduation, etc.), and the statutory basis for release.
- Offer to pay lawful fees immediately; attach receipts if already paid.
- Request release within a definite period (e.g., 5–10 working days) suitable to your exam filing window.
Escalate internally
- Copy the University President and Legal Affairs; keep everything in writing.
File an administrative complaint
- CHED Regional Office (for HEIs) for refusal to release records or for imposing unauthorized conditions; ask for urgent directive due to PRC deadlines.
- PRC Regional Office/Professional Board to inform them of the obstruction and seek guidance on interim filings (some boards accept follow-up of documents if the registrar delays, provided requirements are ultimately met—procedures vary by profession).
Seek judicial relief (time-sensitive cases)
- A civil action for specific performance and damages; in urgent cases, apply for injunctive relief to compel issuance pending trial if you can show a clear right and exam deadlines.
Criminal and related remedies (case-by-case)
- If there’s threats or intimidation to stop you from taking the exam, consult counsel on grave coercion or other offenses.
- For reputational smears or publication of “blacklists,” assess defamation and Data Privacy Act implications.

Common scenarios—and how the law treats them

“The registrar won’t add the ‘for board exam’ remark.” If you’ve graduated and met the program requirements, refusing to annotate the transcript as PRC requires—just to filter candidates—is improper. The registrar’s duty is to accurately reflect your status and comply with standard PRC formatting.
“They’ll release only if I enroll in their review tie-up.” Conditioning records on a commercial tie-in is an unreasonable restraint and can be challenged with CHED and, where applicable, DTI/competition and consumer laws.
“I still have a small balance.” Schools may withhold records for unpaid lawful fees. The solution is usually to settle or negotiate a document-release plan (e.g., pay the TOR fee and any approved balance). However, the school cannot inflate or invent charges or use the debt as a pretext to stop you from sitting the board because of pass-rate optics.
“They say only top-quartile grads get certification this cycle.” Unlawful. There is no law authorizing a school to ration PRC eligibility by rank once the degree is earned.

Risks to schools that engage in pass-rate gatekeeping

CHED sanctions (ranging from orders to comply, to fines, to program suspension in chronic/serious cases).
Civil damages under abuse-of-rights principles (loss of income from delayed licensure, moral/exemplary damages where bad faith is shown).
Criminal exposure (e.g., grave coercion) if threats/intimidation are used.
Data-privacy complaints for public “blocking lists” or disclosures that are not necessary or lawful.

Good-practice guidance for registrars and deans

Publish clear timelines and fees for records release; meet them.
Keep licensure-exam support services (review classes, advising) strictly voluntary.
Never link records release to predicted pass rates or marketing targets.
Document legitimate reasons for any delay (e.g., pending grade submission) and give a dated written notice with a realistic completion date.

Key takeaways

Schools cannot lawfully block graduates from taking PRC board exams to preserve a 100% passing rate.
The school’s role is to certify, not to license or select examinees.
Graduates are entitled to timely release of transcripts and certifications upon payment of lawful fees.
Improper withholding can lead to CHED action, civil damages, and potential criminal liability.
If obstructed, act promptly: make a written demand, escalate to CHED/PRC, and consider court relief if timing is critical.

Disclaimer

This article provides general legal information based on Philippine law and regulatory practice. It is not legal advice for any specific case. For time-sensitive or contested situations, consult a Philippine lawyer and/or immediately coordinate with the relevant CHED Regional Office and PRC office for the profession involved.