Title
Joint MOH-MOLE Accreditation Committee for Medical Clinics vs. Court of Appeals
Case
G.R. No. 78254
Decision Date
Apr 25, 1991
Ermita Medical Center's accreditation was revoked under unpublished 1983 rules; SC ruled them unenforceable due to lack of publication, invalidating the revocation.

Case Summary (G.R. No. 78254)

Applicable Law and Legal Framework

The case is governed by the 1987 Philippine Constitution and the Revised Administrative Code, specifically referencing Section 79(B), which empowers department heads to promulgate rules, regulations, and orders related to their jurisdiction. The accreditation rules in question were established to regulate medical services offered to workers intending to work overseas, ensuring that only qualified and physically fit individuals are sent abroad.

Facts and Procedural History

Ermita Medical Center initially received accreditation as an in-house medical clinic servicing only Builders and Heavy Equipment Services Corporation (BHESCO). This accreditation was first revoked based on the allegation that the Center was conducting medical examinations for other companies. Although the Center managed to have its accreditation reinstated in April 1984, it subsequently faced another revocation in November 1984, leading to its appeal to both the Health and Labor Ministers. The Center's legal challenge culminated in a petition for certiorari with the Court of Appeals in January 1985, which led to the legal discourse on the Committee's authority and the nature of its regulations.

Court of Appeals Findings

The Court of Appeals validated the Committee's enactment of the Rules and Regulations as a legitimate exercise of police power aimed at maintaining the health standards necessary for overseas employment. However, the court concluded that the Committee exceeded its authority by revoking Ermita Medical Center's accreditation, as such action was not within the committee's prescriptive powers according to the established rules. Instead, it was only permitted to recommend sanctions, not to impose them directly. Consequently, the appellate court annulled the accreditation revocation, reinstating the Center's status.

Argument by Solicitor General

In the appeal, the Solicitor General supported the Committee's actions, arguing that it possessed the authority to impose administrative sanctions, including revocation of accreditation. This distinction was made between civil sanctions and penal sanctions, with the former being within the Committee’s purview. The Solicitor General also addressed contentions of favoritism towards other accredited clinics.

Respondent's Contentions

The private respondent, Ermita Medical Center, raised concerns about the Committee's capacity to classify clinics and contested the validity of the accreditation process based on claims that other clinics had been offered full accreditation while it had been denied. Additionally, the Center highlighted the failure of the Rules and Regulations to be published, raising the legal issue of their enforceability.

Legal Significance of Publication

The Supreme Court emphasized the necessity for rules and regulations to be duly published to be enforceable, citing precedent from the case of Tanada v. Tuvera. Since the Rules and Regulations in question ha

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