Facts:

The case involves the Private Hospitals Association of the Philippines, Inc. (PHAPI), represented by its President, Dr. Rustico Jimenez, as the petitioner against Hon. Salvador Medialdea, the Executive Secretary, and the Acting Secretary of the Department of Health as respondents. The petition was filed on November 6, 2018, challenging the constitutionality of certain provisions of Republic Act No. 10932, also known as the Act Strengthening the Anti-Hospital Deposit Law. This law was enacted to prevent hospitals and medical clinics from demanding deposits or advance payments for the confinement or treatment of patients in emergency or serious cases. The petitioner contended that the law imposed 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 yet ruled on the constitutionality of the law, prompting PHAPI to seek a declaration of unconstitutionali...

Facts:

The petitioner, Private Hospitals Association of the Philippines, Inc. (PHAPi), challenged the constitutionality of certain provisions of Republic Act No. 10932, known as the Act Strengthening the Anti-Hospital Deposit Law. Specifically, PHAPi contested:

1. Section 1: The duty imposed on hospitals and medical practitioners to prevent death or injury in emergency cases.
2. Section 4: The penal provisions for violations.
3. Section 5: The presumption of liability clause.
4. Sections 7 and 8: The reimbursement and tax deduction clauses for treating poor and indigent patients.

PHAPi argued that these provisions violated substantive due process, the presumption of innocence, equal protection, and the prohibition against involuntary servitude. The law, which amended previous legislation (Batas Pambansa Bilang 702 and Republic Act No. 8344), aimed to penalize hospitals and clinics that refuse to provide emergency treatment without advance payment.

Issue:

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Ruling:

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Ratio:

1. Judicial Review: The Court emphasized that the power of judicial review requires an actual case or controversy, legal standing, and the raising of constitutional issues at the earliest opportunity. These requisites were not met in this case.
2. Presumption of Constitutionality: Laws enjoy a presumption of constitutionality, which cannot be overturned absent a clear showing of grave abuse of discretion or infraction of the Constitution.
3. Legal Standing of Associations: While associations can sue on behalf of their members, they must demonstrate authorization and a direct interest in the case. PHAPi failed to meet these requirements.
4. Ripeness Doctrine: A case is ripe for adjudication only if there is an actual or imminent injury resulting from the challenged governmental act. PHAPi presented only hypothetical scenarios, which are insufficient.