G.R. No. 207132 & 207205, December 6, 2016
ASSOCIATION OF MEDICAL CLINICS FOR OVERSEAS WORKERS, INC. (AMCOW) and HON. ENRIQUE T. ONA, in his capacity as Secretary of the Department of Health, Petitioners, vs. GCC APPROVED MEDICAL CENTERS ASSOCIATION, INC. AND CHRISTIAN CANGCO, Respondents.

FACTS

Respondent GCC Approved Medical Centers Association, Inc. filed a Petition for Certiorari and Prohibition with the Regional Trial Court (RTC) of Pasay City. The petition sought to nullify Department of Health (DOH) Orders dated August 23, 2010 and November 2, 2010, which implemented certain provisions of Republic Act No. 10022 and its Implementing Rules and Regulations concerning the accreditation of medical clinics for overseas workers. The RTC granted the petition, issuing a writ of certiorari declaring the DOH Orders void and a writ of prohibition directing the DOH Secretary to cease their implementation. The petitioners elevated the case to the Supreme Court.

ISSUE

The core issue, as framed in Justice Leonen’s Concurring and Dissenting Opinion, is whether the Regional Trial Court of Pasay City had jurisdiction to issue the writs of certiorari and prohibition with nationwide effect against the Department of Health.

RULING

Justice Leonen concurred in the result of granting the petitions, thereby nullifying the RTC’s decision, but dissented from the main decision’s doctrinal discussions. He held that the RTC of Pasay City indeed had original jurisdiction under Batas Pambansa Blg. 129 to entertain the special civil actions for certiorari and prohibition. However, the RTC acted without jurisdiction in granting the writs with a scope that was nationwide in effect. The assailed DOH Orders were operative across the entire country, and the respondent association failed to demonstrate that all its affected members were situated solely within the territorial jurisdiction of the Pasay RTC. Consequently, the RTC’s decision was void for having been issued without jurisdiction. Justice Leonen further expressed that it was unnecessary to bifurcate the Court’s certiorari powers into “traditional” and “expanded” modes, as the Constitution’s grant of judicial power to review acts for grave abuse of discretion is sufficient and encompasses violations of statutes or treaties, not just constitutional issues. He also emphasized the requirement of an actual case or controversy for judicial review, cautioning against treating petitions for certiorari as substitutes for declaratory relief.