Case Digest (G.R. No. 194561) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Drugstores Association of the Philippines, Inc. and Northern Luzon Drug Corporation v. National Council on Disability Affairs, G.R. No. 194561, decided on September 14, 2016, petitioners–two major drugstore associations–sought to annul the Court of Appeals’ July 26, 2010 Decision and November 19, 2010 Resolution in CA-G.R. SP No. 109903. The CA had dismissed their Petition for Prohibition and upheld the constitutionality of the mandatory twenty percent (20%) discount on the purchase of medicine by persons with disability (PWDs) under Republic Act No. 7277 (Magna Carta for Disabled Persons, 1992), as amended by RA 9442 (2007). The enactment of RA 9442 expanded the rights of PWDs to a 20% discount on medicines and provided tax deductions for establishments granting such discounts. The law’s Implementing Rules and Regulations (IRR), NCDA Administrative Order No. 1, DOF Revenue Regulations No. 1-2009, and DOH Administrative Order No. 2009-0011 further detailed guidelines on proof Case Digest (G.R. No. 194561) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Legislative Background
- Republic Act No. 7277 (1992) – “Magna Carta for Disabled Persons”:
- Defines “disabled persons,” “impairment,” and “disability.”
- Declares State policy to rehabilitate and integrate disabled persons.
- Republic Act No. 9442 (2007) – Amending RA 7277:
- Renames beneficiaries as “persons with disability (PWD).”
- Grants PWDs a 20% discount on medicine purchases.
- Allows establishments to deduct cost of discounts from gross income.
- Implementing Rules and Administrative Issuances
- Joint IRR of RA 9442 (2008):
- Confirms PWD definitions and discount privilege for medicines.
- Requires proof of entitlement (LGU-issued ID, passport, NCDA fare ID).
- Prescribes tax-deduction mechanics for establishments.
- NCDA Administrative Order No. 1, s. 2008:
- Establishes PWD-ID issuance procedures via LGUs.
- Specifies documentary requirements by type of disability (apparent vs non-apparent).
- DOF Revenue Regulations No. 1-2009:
- Details conditions under which establishments deduct discounts from gross income.
- DOH Administrative Order No. 2009-0011:
- Prescribes prescription and record-keeping requirements for medicine discounts.
- Limits dispensing to one-month supply, mandates special register for PWD transactions.
- Procedural History
- Petition for Prohibition filed by Drugstores Association (July 28, 2009) seeking to enjoin RA 9442 and its IRR, NCDA A.O. No. 1, DOF RR No.1-2009, and DOH A.O. No. 2009-0011.
- Court of Appeals Decision (July 26, 2010):
- Upheld constitutionality of statutes and issuances.
- Suspended effectivity of NCDA A.O. No. 1 pending proof of publication and registration.
- CA Resolution (Nov 19, 2010):
- Dismissed motions for reconsideration by petitioners.
- Lifted suspension after proof of NCDA A.O. No. 1 publication and ONAR filing.
- Petition for Review on Certiorari filed with the Supreme Court; petitioners pray for annulment of CA rulings and injunctive relief.
Issues:
- Whether the mandatory 20% PWD discount constitutes a valid exercise of police power or an invalid exercise of eminent domain requiring compensation.
- Whether Section 32 of RA 7277 (as amended) and related issuances violate substantive due process.
- Whether the statutory and IRR definitions of “disability” are vague, ambiguous, or unconstitutional.
- Whether the 20% discount on medicines violates the equal protection clause by unfairly singling out drugstores.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)