Title
Private Hospitals Association of the Philippines, Inc. vs. Medialdea
Case
G.R. No. 234448
Decision Date
Nov 6, 2018
The court dismisses the petition against the law banning advance payment for emergency medical treatment due to lack of standing and absence of an actual case or controversy.
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Case Digest (G.R. No. 234448)

Facts:

  • The case involves the Private Hospitals Association of the Philippines, Inc. (PHAPI), represented by Dr. Rustico Jimenez, as the petitioner.
  • Respondents include Hon. Salvador Medialdea, the Executive Secretary, and the Acting Secretary of the Department of Health.
  • The petition was filed on November 6, 2018, challenging the constitutionality of certain provisions of Republic Act No. 10932, known as the Act Strengthening the Anti-Hospital Deposit Law.
  • This law prohibits hospitals and medical clinics from demanding deposits or advance payments for emergency or serious cases.
  • PHAPI argued that the law imposes undue burdens on hospitals and medical practitioners, violating their rights to substantive due process, equal protection, and the presumption of innocence.
  • The lower court had not ruled on the law's constitutionality, prompting PHAPI to seek a direct declaration from the Supreme Court.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court dismissed PHAPI's petition.
  • The Court ruled that while certiorari and prohibition are appropriate remedies to challenge a law's constitutionality, the petitioner lacked legal standing.
  • PHAPI failed to demonstrate an actual case or controversy,...(Unlock)

Ratio:

  • The Court emphasized the need for an actual case or controversy for judicial review, requiring a conflict of legal rights resolvable by the courts.
  • As an association, PHAPI could not show a personal st...continue reading

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