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plain, speedy, and adequate remedy in the ordinary course of law.[46]
An administrative agency's exercise of quasi-legislative powers may be questioned and
prohibited through an ordinary action for injunction before the Regional Trial Court
(RTC).[47] The petitioners failed to explain their premature resort to certiorari and their
disregard for the hierarchy of courts, these procedural grounds warrant the outright
dismissal of their petition.
Even if the procedural issues are disregarded, the petitions still failed to show that
PhilHealth gravely abused its discretion in issuing the assailed circulars. On the
contrary, PhilHealth acted with reasonable prudence and sensitivity to the public's
needs. It postponed the rate increase several times to relieve the public of the burden
of simultaneous rate and price increases. It accommodated the stakeholders and heard
them through consultation. In the end, it even retained a lower salary bracket ceiling
(Php35,000.00 instead of Php50,000.00) and a lower rate (2.5% rather than the
planned 3%).
The term "grave abuse of discretion" has a specific and well-defined meaning in
established jurisprudence. It is not an amorphous concept that can be shaped or
manipulated to suit a litigant's purpose.[48] Grave abuse of discretion is present when
there is such capricious and whimsical exercise of judgment as is equivalent to lack of
jurisdiction,[49] or where power is exercised arbitrarily or in a despotic manner by
reason of passion, prejudice, or personal hostility amounting to an evasion of positive
duty, or to a virtual refusal to perform a legal duty or act at all in contemplation of law.
[50]
Other than a sweeping allegation of grave abuse of discretion under its Nature of the
Petition section,[51] the petition is devoid of substantial basis.
PhilHealth has the mandate of realizing the State's vision of affordable and accessible
health services for all Filipinos, especially the poor.[52] To realize this vision and
effectively administer the Program, PhilHealth is empowered to promulgate its policies,
and to formulate a contribution schedule that can realistically support its programs.
PhilHealth justified the increase in annual premium rates with the enhanced benefits
and the expanded coverage of medical conditions.[53] This reasonable decision to widen
the coverage of the program - which led to increased premium rates - is a business
judgment that this Court cannot interfere with.
This Court does not have administrative supervision over administrative agencies, nor
is it an entity engaged in making business decisions. We cannot interfere in purely
administrative matters nor substitute administrative policies and business decisions
with our own. This would amount to judicial overreach. The courts' only concern is the
legality, not the wisdom, of an agency's actions. Policy matters should be left to policy
makers.
The petitioners argue that the new schedule does not conform to the NHIA's standard
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