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representatives[33] and the affected stakeholders before implementing the increase.
The Php2,400.00 minimum annual contribution for all members is equivalent to the
amount that the Government annually incurs to maintain coverage for the poorest of
the poor. Php1,000.00 is allotted for drugs and medicine, Php300.00 for administrative
costs, Php500.00 for consultation, and Php600.00 for in-patient services.[34]
As the premium rate for "the poorest of the poor" was set at Php2,400.00, the rates for
the Employed Sector, the OWP, and the IPP were likewise increased to avoid a situation
where the poorest would contribute a premium higher than that contributed by an
employed member, an OFW, or an individually paying member.[35]
PhilHealth counters that not only did it defer the rate increase to relieve the public of
the simultaneous burden of increases in fees, tolls, taxes, and social security
contributions, but it even introduced the corresponding enhancements in the benefit
packages in 2012 before the premium rates were increased.[36]
With respect to the allegations of outrageously unconscionable bonuses, PhilHealth
argues that these have no logical relation to the increase in premiums. In any case,
COA's disallowance of these items are presently under appeal and sub-judice.[37]
Lastly, PhilHealth prays for the dismissal of the petition arguing: (1) that it was filed out
of time;[38] (2) that it failed to state the material dates as required by Rule 46, Section
3 of the Rules of Court;[39] (3) that the petitioners have no legal standing;[40] (4) that
the petitioners disregarded the hierarchy of courts because the issue was not of
transcendental importance;[41] and (5) that the petition has neither basis nor merit.[42]
OUR RULING
We DISMISS the petition for lack of merit.
At the outset, we stress the settled principle that a sitting head of state enjoys
immunity from suit during his actual tenure.[43] The events that gave rise to the
present action and the filing of the case occurred during the incumbency of President
Aquino. Moreover, the petition contains no allegations as to any specific presidential act
or omission that amounted to grave abuse of discretion. Therefore, it is only proper to
drop the President as a party-respondent.
Under the NHIA, all citizens of the Philippines are required to enroll in the
Program; membership is mandatory.[44] In other words, the NHIP covers all Filipinos
in accordance with the principles of universality and compulsory coverage.[45]
Ultimately, every Filipino is affected by an increase in the premium rates. Thus, the
petitioners have sufficient legal standing to file the present suit.
Nevertheless, the petitioners availed of the wrong remedy in coming to this Court.
Certiorari is a remedy of last resort available only when there is no appeal or any
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