G.R. No. 246710-15 - Quezon City Eye Center vs. Philippine Health Insurance Corp.

The case involves a petition for review on certiorari filed by Quezon City Eye Center against the Philippine Health Insurance Corporation (PhilHealth) and its various departments.
The petition challenges the Court of Appeals' decision affirming the petitioner’s liability for multiple counts of Breach of the Warranties of Accreditation and dismissing other petitions for certiorari.
The case is rooted in allegations of irregularities in the recruitment of patients for cataract surgeries.

PhilHealth issued Circular No. 17 in 2007, suspending claims for cataract surgeries performed under certain conditions, including recruitment schemes.
A complaint was filed against certain doctors, leading to an investigation by PhilHealth's Fact Finding Investigation and Enforcement Department (FFIED).
The investigation identified Dr. Valdez and Dr. Yadao as involved in "cataract sweeping" and recruitment activities, prompting administrative cases against the Quezon City Eye Center.

The FFIED submitted findings indicating that Dr. Valdez performed numerous cataract surgeries, leading to a complaint against the Quezon City Eye Center for Breach of Accreditation Warranties.
The Arbitration Office found the center guilty and imposed fines and penalties, which were subsequently modified upon appeal to the PhilHealth Board.

The Court of Appeals dismissed the consolidated petitions from the Quezon City Eye Center, affirming the PhilHealth Board's decisions.
The appellate court ruled that the petitioner was afforded due process and that the evidence supported the findings of irregularities.

The petitioner contended that it was not involved in any recruitment schemes and that its role was limited to providing facilities for surgeries.
It argued that it was deprived of the opportunity to confront witnesses and that the complaints filed against it lacked a prima facie basis.

PhilHealth maintained that the petitioner was given ample opportunity to respond to allegations and that substantial evidence supported the claims of misconduct.
It argued that the doctrine of apparent authority made the petitioner liable for the actions of the doctors using its facilities.

The Supreme Court found that PhilHealth violated the petitioner’s right to due process by failing to provide a copy of the resolution finding a prima facie case against it.
The Court emphasized that due process requires that a party be informed of the charges against them and given an opportunity to respond.