Tondo Medical Center Employees Association vs Court of Appeals

Facts:
DOH launched Health Sector Reform Agenda to reform the local health system. It was
formed in order to provide fiscal autonomy to government hospitals, secure funding for
priority public programs, promote the development of local health systems and ensure its
effective performance, strengthen the capacities of health regulatory agencies and expand
the National Health Insurance program. However, the petitioners alleged that the
implementation of the HSRA had resulted in making free medicine and medical services
inaccessible to economically disadvantaged Filipinos. They alleged that the HSRA is void
for being in violation of several constitutional provisions (e.g. Art III Sec 1, Art II Sec 5,
Art II Sec, 9, etc.)
EO 102 was the order to redirect the functions and operations of the Department of health
which provided for the changes in the roles functions and organizational processes of the
DOH. Under the assailed order, DOH refocused its mandate from being the sole provider
of health services to being a provider of specific health services and technical assistance,
as a result of being the devolution of basic services to local government units. Petitioners
alleged that this EO is in excess of the Presidential Authority.
Issue:
Whether or Not the HSRA and EO no. 102 are unconstitutional
Ruling:
No, HSRA and EO 102 are not unconstitutional. The HSRA cannot be nullified based
solely on petitioners allegations that it violates the general principles. The argument that
the EO 102 is in excess of the presidential authority due is without basis. Records are
devoid of any explanation of how HSRA violated the equal protection and due process
clauses that are embodied in the Sec 1 Art III of Consti. Petitioners failed to substantiate
how the constitutional guarantees were breached and petitioners are unsuccessful in
establishing the relevance of this provision to the petition.
With the EO 102, the constitution clearly states that the president shall have control of all
executive departments, bureaus and offices. Furthermore, DOH is among the cabinet
level departments enumerated under the Book IV of the Administrative code mainly
tasked with the functional distribution of the work of the president.