Can architects engage in the practice of interior design?

A few months ago, the Supreme Court (SC) promulgated its Decision on the case of Department of Public Works and Highways vs. Philippine Institute of Civil Engineers, Inc. (G.R. No. 200015, March 15, 2023). The case stemmed from a Petition for Declaratory Relief filed by the Philippine Institute of Civil Engineers (PICE), where they asked the Regional Trial Court of Manila to declare certain provisions of the Implementing Rules and Regulations (IRR) of Republic Act No. 9266  — also known as the Architecture Act of 2004 — to be unconstitutional. PICE argued that the practice of civil engineering includes the power to prepare, sign, and seal those “Architectural Documents” under Section 302(4) of the said IRR, as provided by Republic Act No. 544, or the Civil Engineering Law, and the National Building Code.

The United Architects of the Philippines (UAP) moved to intervene in the PICE Petition, alleging, in essence, 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 an architect registered and licensed under the Architecture Act of 2004.” The Supreme Court, in a 40-page Decision, ruled that:

“1. Only registered and licensed architects may prepare, sign, and seal the following architectural documents:

  1. Architectural Plans/Drawings


2.Only registered and licensed architects, or interior designer may prepare, sign, and seal the following architectural interior/interior design documents:

  1. Space Plan/s or layout/s of architectural interior/s.
  2. Architectural interior perspective/s.
  3. Furniture/furnishing/equipment/process layout/s.
  4. Access plan/s, parking plan/s and the like.
  5. Detail design of major architectural interior elements.
  6. Plan and layout of interior, wall partitions, furnishing, furniture, equipment/appliances at a scale of at least 1:100.
  7. Interior wall elevations showing: finishes, switches, doors and convenience outlets, cross window sections with interior perspective as viewed from the main entrance at scale of at least 1:100.
  8. Floor/ceiling/wall patterns and finishing details.
  9. List of materials used.
  10. Cost Estimates.

The SC ruled that certain provisions of the Architectural Act of 2004 (which became effective on April 10, 2004) are “irreconcilably inconsistent” with the Civil Engineering Law (which was approved by Congress on June 17, 1950). The language of Republic Act No. 9266 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. Taking into consideration the irreconcilable conflict between the two laws, SC recognized that Republic Act No. 9266 has impliedly repealed Republic Act No. 544 insofar as it permits civil engineers to prepare, sign, and seal architectural documents.

The SC put a finis on the long-standing friction between licensed architects and licensed civil engineers on the issue of who are empowered to sign building and construction documents. The rationale of the SC in DPWH vs. PICE seems to show that it recognized a profession – architecture – which has more expertise and nuance relating to buildings and  construction, based on the language of the Architectural Act of 2004. Both professions have been regulated by the Philippine government since the year 1950, and it is only in 2023 where the SC resolved fundamental issues as to the capabilities of the practitioners of both.

As confirmed by the SC in DPWH vs. PICE, licensed architects may prepare, sign, and seal “architectural interior/interior design documents”. However, this raises the question: can licensed architects do these actions, in light of the recent passage of interior design laws of the Philippines?

On February 23, 1998, our Congress passed into law Republic Act No. 8534, also known as the Philippine Interior Design Act of 1998. This law was eventually repealed by Republic Act No. 10350, otherwise knowns as the “Philippine Interior Design Act of 2012”. Both laws created, defined, and regulated the professional practice of Interior Design in the Philippines. Section 4(a) of the R.A. No. 10350 defines “Interior Design” as:

“The science and art of planning, specifying, selecting and organizing the surface finishes and materials including furniture, furnishings and fixtures and other interior design elements for the purpose of the interior space allocations to suit, enhance and meet the intended function, movement and character for which the interior of the building is designed.”

Under the same law, prospective interior designers have to undergo a licensure examination supervised by the Professional Regulatory Board of Interior Design under the administrative control and supervision of the Professional Regulation Commission (PRC). Applicants shall complete, among others, a degree of interior design from a reputable institution, and pass the licensure examinations covering the following subjects: (a) Interior Design; (b) Furniture Design and Construction; (c) Materials of Design and Decoration; (d) History of Arts and Interior Design; (e) Interior Construction and Utilities; (f) Color Theory; and (g) Professional Practice and Ethics. Once an applicant has passed the board examinations, and has taken their oath, they become a licensed interior designer (IDr).

The author humbly submits that the arguments of UAP against PICE apply mutatis mutandis for the situation of licensed interior designers as regards their capability to practice those acts covered by the definition of “interior design,” as stated above. Put differently, an IDr shall have the sole and exclusive power to execute interior design documents in the Philippines, in the same sense that licensed architects shall have the sole and exclusive power to execute architectural plans and drawings, for the following reasons:

First. The Philippine Interior Design Act of 2012 impliedly repealed the Architecture Act of 2004. Section 41 of the former law provides that “[a]ll other laws, decrees, executive orders and administrative issuances or parts thereof which are inconsistent with the provisions of this Act are hereby modified, superseded and/or repealed accordingly.”

There is a principle under our laws that if a statute of later date clearly reveals an intention on the part of the legislature to abrogate a prior act on the subject, that intention must be given effect. One method is to check if there is an “irreconcilable inconsistency” between the two laws. In this case, one law relates to the practice of interior design, while the other relates to the practice of architecture — however, both laws contain provisions regarding the preparation, signing and affixing of seals in “interior design” documents.

In DPWH vs. PICE, licensed architects were declared to be empowered to sign “architectural interior/interior design” documents, but  Section 27 of the Philippine Interior Design Act of 2012 expressly provides that government officials charged with enforcement of laws, etc. shall only accept those interior plans, specifications and contract documents relating to construction or alteration of interiors of buildings as prepared by or under the supervision of an IDr, to wit:

A duly registered interior designer shall sign and affix the seal as approved and provided by the Board on all plans, specifications and contract documents prepared by him/her and/or under his/her direct supervision during the validity of his/her certificate of registration.

Officers and/or employees of the government, chartered cities, provinces, municipalities now or hereafter charged with the enforcement of the laws, ordinances or regulations relating to the construction or alteration of the interiors of buildings shall accept only those interior plans, specifications and contract documents which have been prepared by or under the supervision of a duly licensed interior designer and signed and sealed by him/her and submitted in full accord with the provisions of this Act.

Violation of the foregoing shall be ground for administrative and/or criminal action.

In fact, Section 40 of the IRR of the Philippine Interior Design Act of 2012 further emphasizes the exclusive power of an IDr on these matters, by emphasizing that interior plans, specifications and contracts can only be prepared, signed, and sealed by an IDr, “without substitution by an architect, engineer or contractor.” This is an irreconcilable inconsistency between the two laws, because the law is explicit: government officials shall only accept those documents relating to interior design, which are prepared, signed, and sealed by an IDr.

Second. The legislature, through the Philippine Interior Design Act of 2012, recognized the important role of the interior design profession in the Philippines. Undoubtedly, under Section 2 of the said law, the Philippine government “promote[s] the sustained development of professional interior designers, whose technical competencies have been determined by honest and credible licensure examinations and whose standards of professional service and practice are internationally recognized and considered globally competitive, brought about by regulatory measures and human resource programs and activities that foster their professional growth and advancement.”

Congress specifically recognized the profession of interior design, by defining the scope of the professional practice of interior design, in Section 5 of the same law: planning, designing, specifying, supervising and providing general administration and responsible direction to the functional, orderly and aesthetic arrangement and enhancement of interior spaces. At first glance, these are seemingly vague documents, but a harmonized analysis of the Philippine Interior Design Act of 2012 and its IRR, would reveal that these documents are the following:

    • Schematic interior design development, design development, execution of professional contract documents and programming of construction phases;
    • Preparation of interior design plans, design drawings, interior construction details, and technical specifications;
    • Interior construction administration, supervision, coordination of alteration, preservation or restoration of interior spaces;
    • Contract documents which shall include detailed instructions to the contractor, tender forms, contract documents and specifications;
    • Furniture Footprint Plans;
    • Furniture, Furnishings & Equipment;
    • Reflected Ceiling Plan; and
    • Technical Specifications, which may be detailed written description of construction, workmanship and materials of the interior design work to be undertaken which may be closed or open technical specifications.

Third. IDrs have specific and nuanced education and training aimed to practice the profession of interior design. A Bachelor of Science in Interior Design curriculum has specific Professional Courses totaling to 105 units, with Elective Courses totaling to 18 units, pursuant to CHED Memorandum Order No. 44, series of 2017. These, in addition to the licensure examinations, point to no other conclusion that there is an application of specialized knowledge and training to pursue the practice of interior design.

The Philippines is rapidly developing and enhancing its domestic and global capabilities and standards by recognizing the expertise of professionals with specialized knowledge on particular fields of life. Perhaps it is also high time to delineate the nuances of the expertise and capabilities of licensed architects and IDrs, too.

This article is the sole and personal opinion of its author, Atty. Carlo Gabriel P. Sanchez.