G.R. No. 234448 - Private Hospitals Association of the Philippines, Inc. vs. Medialdea

Prohibited demand of deposits or advance payments as prerequisite for treatment or confinement in emergency/serious cases.
Penalized directors, managers or officers with ₱1,000–₱2,000 fine or 15–30 days imprisonment, or both.

Expanded prohibition to requesting, soliciting, accepting deposits; criminalized refusal to administer treatment and support to prevent death or permanent disability.
Mandated stabilization and transfer procedures if a facility lacked capability; defined “emergency,” “serious case,” “confinement,” “hospital,” “medical clinic,” “emergency treatment and support,” “permanent disability,” and “stabilize.”
Increased penalties: 6 months–2 years 4 months imprisonment or ₱20,000–₱100,000 fine; 4–6 years or ₱100,000–₱500,000 fine if violation pursuant to an established policy.

Expanded scope to include “basic emergency care,” defined to cover urgent diagnosis, procedures and support, including active labor and safe delivery.
Required free use of LGU emergency vehicles and ACLS-certified nurse accompaniment for transfers; mandated posting of hospital classification and authorized services.

Creation of Health Facilities Oversight Board under DOH to investigate, adjudicate and impose administrative sanctions (including license revocation); membership: DOH director, PhilHealth, PMA, private health, and three NGOs.
Penal and fiscal provisions

Officials, practitioners or employees: 6 months–2 years 4 months imprisonment or ₱100,000–₱300,000 fine; policy-based directors/officers: 4–6 years or ₱500,000–₱1,000,000 fine; three-strike rule for license revocation; solidary liability for damages.
Presumption of liability upon death, permanent disability, serious impairment or loss of unborn child due to deposit policy violation.
PhilHealth reimbursement and PCSO assistance limited to poor/indigent; related expenses tax-deductible.

DOH Administrative Order No. 2018-0012 (Apr. 4, 2018) implementing RA 10932.
PHAPi filed Petition for Certiorari and Prohibition (G.R. No. 234448, Nov. 6, 2018), challenging as unconstitutional Sections 1 (duty to administer basic emergency care), 4 (penal provisions), 5 (presumption of liability), 7–8 (reimbursement and tax deductibility clauses) on grounds of substantive due process, presumption of innocence, equal protection and involuntary servitude.

Are certiorari and prohibition proper remedies to assail a legislative act under the Supreme Court’s expanded jurisdiction?
Is direct resort to the Supreme Court justified in view of the doctrine of hierarchy of courts?
Has PHAPi demonstrated ripeness and an actual controversy?
Does PHAPi have the requisite locus standi as an association of private hospitals?

Section 1: Does the duty to administer basic emergency care violate substantive due process by imposing an impossible guarantee of preventing death or disability?
Section 4: Are the fines, imprisonment ranges and solidary liability provisions unjust, excessive or oppressive in violation of equal protection or due process?
Section 5: Does the presumption of liability clause infringe the constitutional presumption of innocence and require unlawful causation presumptions?
Sections 7 and 8: Do restrictions on PhilHealth reimbursement, PCSO assistance and tax deductions to poor/indigent patients violate equal protection and amount to involuntary servitude?