Cited Laws
TL;DR — Ruling
WHEREFORE , in view of the foregoing, the instant Petition is GRANTED . The Letters dated August 7, 2020 and December 15, 2020 issued by the [PhilHealth] Office of the Area Vice President, Area II – South Luzon and Concurrent Vice President – PRO NCR and of the Phil[H]ealth Office of the President and CEO, respectively, withdrawing Dr. Jose Mari Galauran's accreditation as a health care professional, are SET ASIDE . SO ORDERED .
WHEREFORE , in view of the foregoing, the instant Petition is GRANTED . The Letters dated August 7, 2020 and December 15, 2020 issued by the [PhilHealth] Office of the Area Vice President, Area II South Luzon and Concurrent Vice President PRO NCR and of the Phil[H]ealth Office of the President and CEO, respectively, withdrawing Dr. Jose Mari Galauran's accreditation as a health care professional, are SET ASIDE . SO ORDERED . [52] (Emphasis in the original) The appellate court ruled that the authority to withdraw or revoke an existing accreditation is vested with the PhilHealth Board. [53] It further clarified that the initial process of accreditation and its revocation or withdrawal are two separate processes and exercised by distinct entities. [54] Thus, Dr. Galauran's accreditation was revoked arbitrarily and without lawful authority. [55] With regard to the issue on due process, the CA found that Dr. Galauran's right was violated by PhilHealth. [56] In particular, PhilHealth failed to furnish a copy of the document showing that Dr. Galauran allegedly received the amount of PHP 6,650.00 from its office for the ghost dialysis sessions of Albante. [57] The appellate court also ruled that the revocation of Dr. Galauran's accreditation was not supported by substantial evidence. [58] In fact, the documentary evidence presented by PhilHealth revealed that: (1) the deceased patient's attending physician was a certain Dr. Natividad, not Dr. Galauran; and (2) the computer-generated report only showed Dr. Galauran's name in the column of list of professionals, and proved that he did not prepare any report for Albante. [59] PhilHealth sought reconsideration, [60] but it proved futile. The CA found that the motion for reconsideration raised reiterated, repeated, and rehashed arguments from its appeal, which were thoroughly discussed in its assailed Decision dated September 13, 2023. [61] Thus, the dispositive portion of the CA Resolution [62] dated December 13, 2023 states: WHEREFORE , since there are no compelling grounds or bases sufficient to justify the reversal or modification of Our Decision dated September 13, 2023, the Motion for Reconsideration filed by [PhilHealth] is hereby DENIED for lack of merit. SO ORDERED.