GR 207132; (December, 2016) (Digest)
G.R. No. 207132 & G.R. No. 207205, December 6, 2016
ASSOCIATION OF MEDICAL CLINICS FOR OVERSEAS WORKERS, INC., (AMCOW), ET AL., PETITIONERS, VS. GCC APPROVED MEDICAL CENTERS ASSOCIATION, INC. AND CHRISTIAN CANGCO, RESPONDENTS.
FACTS
The Department of Health (DOH) initially issued Administrative Order (AO) No. 5, series of 2001, establishing a referral decking system for overseas Filipino workers (OFWs) bound for Gulf Cooperation Council (GCC) countries. This system required OFWs to first report to a GCC Approved Medical Centers Association, Inc. (GAMCA) center, which would then refer them to a specific GAMCA-member clinic for their mandatory medical examination. Subsequently, the DOH repealed AO 5-01 through AO No. 167, series of 2004, finding that the decking system did not guarantee safe and quality health services. The DOH later issued cease and desist orders against the system.
GAMCA challenged these orders. Meanwhile, Republic Act No. 10022 (the Migrant Workers Act) took effect, explicitly prohibiting the decking practice and affirming the OFW’s freedom to choose any DOH-accredited clinic. The Regional Trial Court (RTC) ruled in favor of GAMCA, declaring the DOH’s cease and desist orders null and void. The DOH and the Association of Medical Clinics for Overseas Workers, Inc. (AMCOW) elevated the case to the Supreme Court via petitions for review on certiorari.
ISSUE
Whether the Regional Trial Court erred in declaring the DOH’s cease and desist orders against the GAMCA referral decking system null and void.
RULING
Yes, the RTC erred. The Supreme Court reversed the RTC’s decision and upheld the validity of the DOH’s orders. The legal logic rests on the principle that an administrative agency’s interpretation of its own rules and its exercise of regulatory powers are entitled to great respect, especially when aligned with a subsequent legislative act. The DOH, in issuing the cease and desist orders, was acting within its mandate to regulate medical clinics and protect OFWs. Its determination that the decking system was detrimental to OFWs’ rights and welfare was a valid exercise of its quasi-legislative and police powers.
Critically, this administrative action was later expressly affirmed and codified by Congress through RA 10022. The law explicitly prohibits the decking system and guarantees OFWs the freedom to choose their medical clinic. Therefore, the DOH’s orders, which sought to enforce the same policy later embodied in statute, were not only valid but became mandatory. The Court held that the RTC committed grave abuse of discretion in nullifying the DOH’s orders, as they were issued pursuant to the DOH’s regulatory authority and were in complete harmony with the unequivocal prohibition set forth in RA 10022.