Cited Laws
Accordingly, petitioners Philippine Medical Association, [33] Philippine College of Physicians, [34] Integrated Bar of the Philippines, [35] Philippine Dental Association, [36] Association of Small Accounting Practitioners in the Philippines, [37] as well as the Office of the Solicitor General, [38] Department of Finance, [39] and Commissioner of Internal Revenue [40] filed their respective Memoranda. These were noted in this Court's September 27, 2016, [41] October 18, 2016, [42] November 15, 2016, [43] November 22, 2016, [44] January 17, 2017, [45] March 7, 2017, [46] and June 20, 2017 [47] Resolutions. Petitioner Integrated Bar of the Philippines argues that it has legal standing, being "the official national body of all persons whose names appear in the Roll of Attorneys," [48] as its member-lawyers will sustain direct and personal injury under Revenue Regulations No. 4-2014, which penalizes noncompliance. It likewise files this case as a Filipino taxpayer and citizen, on behalf of clients whose rights to privacy will be violated. It also stresses the transcendental importance of the issues here. [49] Petitioner Integrated Bar of the Philippines claims that respondents gravely abused their discretion in issuing Revenue Regulations No. 4-2014. It asserts that complying with it violates ethical standards on lawyer-client privilege and other duties of a lawyer. In imposing penalties, it allegedly forces lawyers to violate their code of ethics, which this Court promulgated. [50] Specifically, it alleges that the revenue regulation encroaches on this Court's rule-making power to protect and enforce constitutional rights and regulate the legal practice. [51] It also avers that the Tax Code does not require professionals to submit an affidavit of fixed service fees and to register their appointment books, making Revenue Regulations No. 4-2014 ultra vires for being outside the scope of the administrative agencies' rule-making power. [52] It also claims that the publication of rates is inconsistent with Canon 20 of the Code of Professional Responsibility, which enumerates the factors in imposing fees and makes room for flexibility. It notes that these fees vary per client and were not meant to be standardized. [53] Finally, it underscores that the revenue regulation infringes on the lawyers and their clients' right to privacy. [54] Similarly, petitioner Philippine College of Physicians assails Revenue Regulations No. 4-2014 as it violates ethical practices and norms on physician-patient confidentiality, altruism, and non-advertisement. [55] It posits that the mandated disclosure of patient names and appointments will produce a chilling effect on access to medical care. It points out that its member-physicians treat individuals with leprosy, tuberculosis, and HIV, whose identities the law explicitly prohibits disclosure. It cautions that their names' disclosure would dissuade them from seeking a physician's services, violating the constitutionally guar