Case Digest (G.R. No. 193158)
Facts:
The case involves the Philippine Health Insurance Corporation (PHIC) as the petitioner and Our Lady of Lourdes Hospital (OLLH) as the respondent. PHIC, a government corporation created under Republic Act No. 7875 as amended, administers the National Health Insurance Program. OLLH is an accredited institutional health care provider with PHIC. On May 14, 2009, PHIC filed a complaint with its Legal Sector - Prosecution Department against OLLH for the administrative offense of filing multiple claims, violating Section 145, Rule XXVIII of the Implementing Rules and Regulations (IRR) of R.A. No. 7875. It was alleged that OLLH filed two claims for the same PhilHealth benefits involving the same patient, diagnosis, and confinement period.
The complaint docketed as HCP-NCR-09-082 was assigned to Senior Arbiter Atty. Darwin G. De Leon, and summons was served to OLLH. OLLH filed a verified answer on June 23, 2009, and was directed to file a position paper. PHIC submitted their position pa
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Case Digest (G.R. No. 193158)
Facts:
- Parties and Background
- Petitioner Philippine Health Insurance Corporation (PHIC) is a government corporation established under R.A. No. 7875, tasked with implementing the National Health Insurance Program.
- Respondent Our Lady of Lourdes Hospital (OLLH) is an institutional health care provider accredited by PHIC.
- Administrative Complaint and Proceedings
- On May 14, 2009, PHIC filed an administrative complaint against OLLH for the offense of filing multiple claims, penalized under Section 145, Rule XXVIII of the Implementing Rules and Regulations (IRR) of R.A. No. 7875. It was alleged that OLLH filed two claims for the same PhilHealth benefits involving the same patient, diagnosis, and confinement period.
- The case was docketed as HCP-NCR-09-082 and assigned to Senior Arbiter Atty. Darwin G. De Leon, with summons duly served to OLLH.
- OLLH filed a Verified Answer on June 23, 2009, and was directed to file a position paper. PHIC complied promptly.
- OLLH moved to defer submission of its position paper pending the answers of the PHIC President and CEO to written interrogatories, and for inspection and copying of certain original documents accompanying the complaint. OLLH claimed these discovery modes were necessary due to denial of access to relevant documents and restricted communication with PHIC personnel.
- PHIC opposed OLLH’s motion; the Arbitration Department, through Arbiter De Leon, denied the motion via an August 11, 2009 Resolution, reasoning that discovery procedures are inconsistent with the summary nature of the administrative proceedings and could delay resolution. The refusal to grant discovery was also justified on the ground that interrogatories were addressed to an incompetent party (PHIC President instead of personnel handling claims), and OLLH’s allegations of denial of access were unsubstantiated and self-serving.
- OLLH filed a Motion for Reconsideration, which was denied by a September 4, 2009 Order affirming the earlier Resolution and emphasizing the Arbiter’s discretion in controlling the procedural conduct consistent with facilitating quick disposition, referencing related legal precedents and procedural rules.
- Appeal to the Court of Appeals (CA)
- OLLH elevated the denial of discovery modes to the CA via a petition for certiorari.
- On July 27, 2010, the CA reversed the Arbitration Department’s Resolution and Order, finding that grave abuse of discretion was committed when modes of discovery were denied. The CA held that OLLH demonstrated good cause for discovery to prepare its defense intelligently and that the information sought was relevant and not privileged.
- Petition to the Supreme Court and Procedural Issue
- PHIC filed a petition for review on certiorari to the Supreme Court, arguing the denial of discovery was proper under the applicable procedural rules, which only recognize answer and position papers in the proceedings before the Arbiter.
- PHIC further contended that the modes of discovery were not a matter of right and could be denied to avoid delay and redundancy, given that relevant facts and documents were already in the record.
- OLLH raised a procedural objection regarding the petition’s defective certification against forum shopping, claiming the signatory was unauthorized.
- The Supreme Court found substantial compliance with certification requirements based on additional resolutions submitted by PHIC showing authorization of the signatory, and held this did not warrant dismissal.
Issues:
- Whether the Court of Appeals erred in annulling and setting aside the PHIC Arbitration Department’s denial of OLLH’s resort to modes of discovery (written interrogatories and production/inspection of documents).
- Whether the petition for review filed by PHIC should be dismissed for failure to comply with the certification against forum shopping requirement under Section 5, Rule 7 of the Rules.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)