Case Digest (G.R. No. 271209)
Facts:
Philippine Health Insurance Corporation (PhilHealth), PhilHealth President and Chief Executive Officer, and PhilHealth Regional Office–National Capital Region, through its Vice President, petitioners, vs. Dr. Jose Mari Del Valle Galauran, respondent, G.R. No. 271209, August 19, 2024, Supreme Court First Division, Hernando, J., writing for the Court.PhilHealth is the GOCC created by Republic Act No. 7875, as amended, charged with administering the National Health Insurance Program and with issuing accreditation guidelines; Dr. Jose Mari D. Galauran was an accredited health care professional (HCP), a nephrologist. In August–October 2018, PhilHealth’s Fact‑Finding Investigation and Enforcement Department (FFIED) conducted spot inspections and claims validation after reports of anomalous claims; one target was WellMed Dialysis and Laboratory Center Corporation. FFIED reported that WellMed filed benefit claims for dialysis sessions of member Bebian Morte Albante dated in August–September 2016 although Albante had died on July 16, 2016.
FFIED alleged that Dr. Galauran certified dialysis sessions after Albante’s death and filed a Complaint‑Affidavit charging him with (1) misrepresentation by furnishing false or incorrect information (RIRR Sec. 162) and (2) breach of warranties of accreditation/performance commitment (RIRR Sec. 163). PhilHealth ordered Dr. Galauran to file a Verified Answer (July 12, 2019); he filed one on August 27, 2019 denying the accusations, asserting he was not Albante’s attending physician, that he did not work at WellMed, and that he did not sign any claims.
Despite his defenses, PhilHealth issued a letter dated August 7, 2020 withdrawing Dr. Galauran’s accreditation (first assailed Order), stating sufficient grounds based on investigations and administrative cases. Dr. Galauran sought reconsideration (Sept. 4, 2020) and argued, among other things, that whistleblowers admitted forging signatures, the patient’s mother did not identify him as attending physician, and PhilHealth failed to furnish the alleged falsified document showing he received PHP 6,650.00. The PhilHealth President and CEO denied his appeal in a letter dated December 15, 2020 (second assailed Order), and PhilHealth notified him on February 3, 2021.
Dr. Galauran filed a petition for certiorari under Rule 65 with the Court of Appeals (CA), arguing that only the PhilHealth Board may revoke accreditation in the exercise of quasi‑judicial power and that he was denied due process. The CA (First Division) granted his petition on September 13, 2023 and set aside PhilHealth’s August 7 and December 15, 2020 letters, holding that withdrawal/revocation is a Board function, that PhilHealth failed to furnish a material document (the payment evidence) and that PhilHealth’s documentary proof did not substantiate the charges; the CA also noted the PhilHealth Arbitration Office dismissed the case against him for insufficiency of evidence (May 31, 2022). PhilHealth’s motion for reconsideration was denied by the CA on December 13, 2023.
PhilHealth filed this Petition for Review on Certiorar...(Subscriber-Only)
Issues:
- Whether Dr. Galauran’s accreditation was revoked arbitrarily and without lawful authority by the PhilHealth President and CEO and the Vice President.
- Whether Dr. Galauran was afforded du...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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