Case Digest (G.R. No. 246710-15)
Facts:
- The case involves the Quezon City Eye Center (petitioner) and the Philippine Health Insurance Corporation (PhilHealth) along with its departments.
- Reports of irregularities in patient recruitment for cataract surgeries led PhilHealth to issue Circular No. 17 in 2007, suspending claims for surgeries performed during medical missions or through recruitment schemes.
- A complaint on September 4, 2009, prompted PhilHealth to investigate several ophthalmologists, including Dr. Allan M. Valdez and Dr. Rhoumel A. Yadao, associated with the petitioner.
- Dr. Valdez performed 1,179 cataract surgeries from July 2009 to June 2010, resulting in multiple administrative cases against the petitioner for Breach of the Warranties of Accreditation.
- The PhilHealth Arbitration Office found the petitioner guilty of 37 counts of Breach of the Warranties of Accreditation, imposing a fine and suspension of accreditation.
- The petitioner appealed, but the PhilHealth Board affirmed the decision, leading to further appeals to the Court of Appeals.
- The Court of Appeals dismissed the consolidated petitions, affirming PhilHealth's findings and ruling that due process was afforded to the petitioner.
- The petitioner then filed a petition for review on certiorari before the Supreme Court, challenging the Court of Appeals' decisions.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled in favor of the petitioner, reversing the decisions of the Court of Appeals and the PhilHealth Board.
- The Court found that the petitioner was not afforded due process due to PhilHealth's failure to provide a copy of the resolution finding a prima facie case against the petitioner.
- The Court c...(Unlock)
Ratio:
- The Supreme Court emphasized that due process in administrative proceedings requires informing the affected party of the charges and providing an opportunity to respond.
- PhilHealth's failure to provide the petitioner with a copy of the resolution finding a prima facie case constituted a violation of due process.
- Substantial evidence is ...continue reading
Case Digest (G.R. No. 246710-15)
Facts:
The case involves the Quezon City Eye Center (petitioner) and the Philippine Health Insurance Corporation (PhilHealth) along with its various departments, including the Arbitration Office, Prosecution Department, and Fact Finding Investigation and Enforcement Department. The events leading to the case began with reports of irregularities in the recruitment of patients for cataract surgeries, prompting PhilHealth to issue Circular No. 17 in 2007, which suspended claims for cataract operations performed during medical missions or through recruitment schemes. Following a complaint received on September 4, 2009, PhilHealth initiated an investigation into several ophthalmologists, including Dr. Allan M. Valdez and Dr. Rhoumel A. Yadao, who were associated with the petitioner.
The investigation revealed that Dr. Valdez performed 1,179 cataract surgeries from July 2009 to June 2010, leading to multiple administrative cases against the petitioner for Breach of the Warranties of Accreditation. The PhilHealth Arbitration Office found the petitioner guilty of 37 counts of Breach of the Warranties of Accreditation, imposing a fine and a suspension of accreditation. The petitioner appealed the decision, which was affirmed by the PhilHealth Board, leading to further appeals to the Court of Appeals. The Court of Appeals dismissed the consolidated petitions of the petitioner, a...