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

The Private Hospitals Association of the Philippines, Inc. (PHAPi) challenges the constitutionality of several provisions of Republic Act No. 10932, claiming violations of substantive due process, the presumption of innocence, equal protection, and involuntary servitude.
The specific provisions contested include:
- Section 1: Duty imposed on hospitals and medical practitioners to prevent death or injury.
- Section 4: Penal provisions for violations.
- Section 5: Presumption of liability clause.
- Sections 7 and 8: Reimbursement and tax deduction clauses.

The legislative framework began with Batas Pambansa Bilang 702 in 1984, prohibiting advance payments for emergency medical treatment.
This was amended by Republic Act No. 8344 in 1997, which expanded prohibitions to include requests for deposits and mandated the provision of emergency treatment.
The most recent amendment, Republic Act No. 10932, further strengthens these provisions, increasing penalties and establishing a presumption of liability for hospitals and medical practitioners in cases of patient harm due to non-compliance.

R.A. No. 10932 prohibits hospitals from demanding deposits for emergency care and imposes severe penalties for violations.
It establishes a Health Facilities Oversight Board to handle complaints and enforce compliance.
The law includes a presumption of liability for hospitals in cases of patient death or injury resulting from the denial of admission due to deposit policies.

PHAPi asserts that the law imposes unreasonable duties on medical practitioners, effectively making them insurers of patient outcomes, which violates due process.
The association argues that the penalties are excessive and not proportionate to the offenses.
The presumption of liability is claimed to be unconstitutional as it contradicts the presumption of innocence.
PHAPi contends that the exclusion of non-indigent patients from reimbursement and assistance violates equal protection rights and constitutes involuntary servitude.

The respondents argue that the petition lacks standing as PHAPi is not a medical institution and thus does not suffer direct injury from the law.
They assert that R.A. No. 10932 does not impose a duty to guarantee patient outcomes but rather prohibits the refusal of emergency treatment based on payment.
The fines and penalties are defended as reasonable and within legislative discretion.
The presumption of liability is justified as it arises only after proof of denial of treatment due to deposit policies.

The Court finds that the petition for certiorari and prohibition is appropriate for challenging the constitutionality of a law.
However, it emphasizes that the requirements for judicial review must be satisfied, including the existence of an actual case or controversy and the standing of the petitioner.

The Court dismisses the petition, concluding that PHAPi lacks the requisite standing as it does not demonstrate a direct injury from the law.
The absence of an actual case or co...continue reading