Case Digest (G.R. No. 119337)
Facts:
In Quezon City Eye Center v. Philippine Health Insurance Corporation, G.R. Nos. 246710–15, decided February 6, 2023 by the Supreme Court’s Second Division, the petitioner, Quezon City Eye Center, is a PhilHealth-accredited facility in Quezon City. Respondent Philippine Health Insurance Corporation (PhilHealth) issued Circulars Nos. 17 and 19, series 2007, to curb recruitment schemes and medical-mission abuses in cataract operations. Pursuant to reports of “cataract sweeping” by two visiting ophthalmologists, Drs. Allan M. Valdez and Rhoumel A. Yadao, PhilHealth’s Fact-Finding Investigation and Enforcement Department conducted domiciliary visits, claim validations, and took affidavits from purported patients. The Prosecution Department then filed six separate Complaints for multiple counts of Breach of the Warranties of Accreditation under Section 150 of the 2004 Revised IRR of R.A. 7875, as amended. The PhilHealth Arbitration Office found the Eye Center liable in three cases, imCase Digest (G.R. No. 119337)
Facts:
- PhilHealth Circulars and Initial Complaint
- PhilHealth issued Circular No. 17 (2007) suspending claims for cataract surgeries performed during medical missions or recruitment schemes, and Circular No. 19 (2007) prescribing guidelines and listing prohibited practices.
- A September 4, 2009 letter‐complaint alleged “cataract sweeping” by certain ophthalmologists, prompting Fact Finding Investigation and Enforcement Department (FFIED) probes of top utilizers.
- Administrative Proceedings Against Quezon City Eye Center (QCEC)
- PHIC Case No. HCP-NCR-12-356 to 392 (CA-G.R. SP 142323) – Dr. Allan M. Valdez performed 1,179 cataract operations (July 2009–June 2010). QCEC was charged with 37 counts of Breach of the Warranties of Accreditation, found guilty by the Arbitration Office, fined and suspended, appeal denied by PhilHealth Board, elevated to CA.
- PHIC Case No. HCP-NCR-12-453 to 458 (CA-G.R. SP 142325) – Dr. Rhoumel A. Yadao’s six cataract operations under recruitment schemes. QCEC faced six counts, similarly found guilty, penalty modified on appeal, petitioned to CA.
- PHIC Case No. HCP-NCR-15-036 to 044 (CA-G.R. SP 151136) – Nine suspect claims for cataract operations by Dr. Yadao, QCEC charged with violations of multiple IRR provisions, found guilty of 15 counts, penalized, appealed to CA.
- PHIC Cases No. HCP-NCR-16-216 to 245 (CA-G.R. SP 146098), 16-580 to 767 (CA-G.R. SP 146172), and 16-291 to 381 (CA-G.R. SP 146173) – QCEC filed Rule 65 certiorari petitions before CA, assailing prosecution for filing complaints without a prima facie resolution.
- Court of Appeals Disposition
- CA consolidated six petitions (CA-G.R. SP 142323, 142325, 151136, 146098, 146172, 146173).
- June 25, 2018 Decision upheld PhilHealth’s liability findings in SP 142323, 142325, 151136 and dismissed certiorari petitions in SP 146098, 146172, 146173 as premature. April 8, 2019 resolution denied reconsideration.
Issues:
- Whether PhilHealth afforded QCEC due process in administrative prosecutions.
- Whether substantial evidence supports QCEC’s liability for Breach of the Warranties of Accreditation.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)