Case Digest (G.R. No. 179786) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On February 6, 2006, Josielene Lara Chan (petitioner) filed a petition before the Regional Trial Court (RTC) of Makati City, Branch 144, seeking a declaration of nullity of her marriage to Johnny T. Chan (respondent), dissolution of their conjugal partnership of gains, and custody of their children. Petitioner alleged that respondent suffered from mental deficiency due to chronic alcohol and prohibited drug use, relying on a psychiatrist’s diagnosis and his subsequent involuntary confinement at a rehabilitation hospital. In his answer, respondent denied the allegations and contended that petitioner had abandoned her wifely duties. During pre-trial, petitioner pre-marked a PhilHealth Claim Form attached to respondent’s answer, bearing a physician’s handwritten note on respondent’s amphetamine and alcohol abuse, and on August 22, 2006 moved for issuance of a subpoena duces tecum directing Medical City to produce respondent’s hospital records, accompanied by a motion to allow those Case Digest (G.R. No. 179786) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Petition for declaration of nullity and related reliefs
- On February 6, 2006, petitioner Josielene Lara Chan filed before RTC Makati Branch 144 a petition for:
- Declaration of nullity of marriage to respondent Johnny T. Chan
- Dissolution of their conjugal partnership of gains
- Award of custody of their children to her
- Allegations included Johnny’s failure to support his family and a psychiatrist’s diagnosis of mental deficiency due to chronic alcohol and prohibited‐drug abuse, leading to his confinement for detoxification and rehabilitation
- Deterioration of marriage relations
- Johnny claimed Josielene failed in her wifely duties; they underwent attempted marriage counseling, during which Johnny was forcibly held and injected against his will
- A subsequent unrelated police detention of Josielene further strained the marriage beyond repair
- Procedural history of subpoena duces tecum request
- During pre‐trial, Josielene pre‐marked a PhilHealth Claim Form attached by Johnny to his answer, showing physician’s note on abuse
- On August 22, 2006, she moved for a subpoena duces tecum to Medical City for Johnny’s hospital records; RTC denied the motion on physician‐patient privilege grounds and likewise denied reconsideration
- Josielene filed a certiorari petition (CA‐G.R. SP 97913), which the Court of Appeals denied on September 17, 2007, upholding the privilege protection over medical records
Issues:
- Whether the Court of Appeals erred in affirming the RTC’s denial of a subpoena duces tecum for Johnny’s hospital records
- Whether Johnny’s hospital records are protected by the physician‐patient privileged communication under Rule 130, Section 24(c), and thus not subject to compulsory production without his consent
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)