Nevertheless, we cautioned in The Diocese of Bacolod, et al. v. COMELEC, et al.,[60] that the Supreme Court's role to interpret the Constitution and act in order to protect constitutional rights when these become exigent is never meant to be emasculated by the doctrine of hierarchy of courts. As such, this Court possesses full discretionary authority to assume jurisdiction over extraordinary actions for certiorari filed directly before it for exceptionally compelling reasons, or if warranted by the nature of the issues clearly and specifically raised in the petition.[61]
As developed by case law, the instances when direct resort to this Court is allowed are enumerated in The Diocese of Bacolod[62] as follows:
(a) when there are genuine issues of constitutionality that must be addressed at the most immediate time;[63]
(b) when the issues involved are of transcendental importance;[64]
(c) in cases of first impression;[65]
(d) the constitutional issues raised are better decided by the Supreme Court;[66]
(e) the time element or exigency in certain situations;[67]
(f) the filed petition reviews an act of a constitutional organ;[68]
(g) when there is no other plain, speedy, and adequate remedy in the ordinary course of law;[69]
(h) the petition includes questions that are dictated by public welfare and the advancement of public policy, or demanded by the broader interest of justice, or the orders complained of were found to be patent nullities, or the appeal was considered as clearly an inappropriate remedy.[70]
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Legal Standing
Closely related to the constitutional mandate that the Court settle only actual cases or controversies is the requirement of legal standing. Invariably, legal standing or locus standi is defined as a personal and substantial interest in a case such that the party has sustained or will sustain direct injury as a result of the governmental act that is being challenged.[84]
As a rule, a party is allowed to raise a constitutional question when (1) he can show that he will personally suffer some actual or threatened injury because of the allegedly illegal conduct of the government; (2) the injury is fairly traceable to the challenged action; and (3) the injury is likely to be redressed by a favorable action.[85]
Sans doubt, R.A. No. 10932 governs the conduct of hospitals, medical facilities, medical practitioners and employees inasmuch as the law imposes upon the latter certain obligations and imposes corresponding sanctions in case of violation. However, petitioner itself, is not a hospital, a medical facility, a medical practitioner or employee, but an association thereof.
On grounds of denial of substantive due process, repugnancy to the constitutional presumption of innocence, violation of the equal protection and involuntary servitude clauses, petitioner Private Hospitals Association of the Philippines, Inc., (PHAPi) - an organization of privately-owned clinics, hospitals, and other health facilities - seeks to declare as unconstitutional and void the duty imposed upon hospitals, medical practitioners and employees to prevent actual death or injury under Section 1; the penal provisions under Section 4; the presumption of liability clause under Section 5; and the reimbursement and tax deduction clause under Sections 7 and 8, all of Republic Act (R.A.) No. 10932[1] otherwise known as an Act Strengthening the Anti-Hospital Deposit Law.
As developed by case law, the instances when direct resort to this Court is allowed are enumerated in The Diocese of Bacolod[62] as follows:
(a) when there are genuine issues of constitutionality that must be addressed at the most immediate time;[63]
(b) when the issues involved are of transcendental importance;[64]
(c) in cases of first impression;[65]
(d) the constitutional issues raised are better decided by the Supreme Court;[66]
(e) the time element or exigency in certain situations;[67]
(f) the filed petition reviews an act of a constitutional organ;[68]
(g) when there is no other plain, speedy, and adequate remedy in the ordinary course of law;[69]
(h) the petition includes questions that are dictated by public welfare and the advancement of public policy, or demanded by the broader interest of justice, or the orders complained of were found to be patent nullities, or the appeal was considered as clearly an inappropriate remedy.[70]
xx
Closely related to the constitutional mandate that the Court settle only actual cases or controversies is the requirement of legal standing. Invariably, legal standing or locus standi is defined as a personal and substantial interest in a case such that the party has sustained or will sustain direct injury as a result of the governmental act that is being challenged.[84]
As a rule, a party is allowed to raise a constitutional question when (1) he can show that he will personally suffer some actual or threatened injury because of the allegedly illegal conduct of the government; (2) the injury is fairly traceable to the challenged action; and (3) the injury is likely to be redressed by a favorable action.[85]
Sans doubt, R.A. No. 10932 governs the conduct of hospitals, medical facilities, medical practitioners and employees inasmuch as the law imposes upon the latter certain obligations and imposes corresponding sanctions in case of violation. However, petitioner itself, is not a hospital, a medical facility, a medical practitioner or employee, but an association thereof.
On grounds of denial of substantive due process, repugnancy to the constitutional presumption of innocence, violation of the equal protection and involuntary servitude clauses, petitioner Private Hospitals Association of the Philippines, Inc., (PHAPi) - an organization of privately-owned clinics, hospitals, and other health facilities - seeks to declare as unconstitutional and void the duty imposed upon hospitals, medical practitioners and employees to prevent actual death or injury under Section 1; the penal provisions under Section 4; the presumption of liability clause under Section 5; and the reimbursement and tax deduction clause under Sections 7 and 8, all of Republic Act (R.A.) No. 10932[1] otherwise known as an Act Strengthening the Anti-Hospital Deposit Law.
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