USA College of Law

VALENCIANA, 1-E
Case Name 13. The People of the Philippines v. Guillermo I. Ventura
Topic Police Power
Case No. | Date G.R. No. L-15079 | January 31, 1962
Ponente BENGZON, C.J.
It is within the police power of the State to require that persons who devote themselves to the
curing of human ills should possess a thorough knowledge for the proper diagnosis of diseases of
Doctrine
the human body, and their possession of such knowledge can be ascertained in an examination of
the parties by competent persons.

RELEVANT FACTS
 In February 1955, Ventura was alleged to have illegally practiced medicine in Pasay City by treating and
applying electrical appliances to patients for the purpose of curing them with their ailments, diseases, pains,
and physical defects from which they are suffering and by holding out himself to the public by means of
signs, advertisements, and other means, to be a Doctor of Medicine even though he is not a duly-licensed
masseur nor a physician qualified to practice medicine.

 CFI of Rizal found accused Ventura guilty of illegal practice of medicine under Section 770 of the Medical
Law in connection with Section 2678 of the Revised Administrative Code. This was his second offense for he
was also found guilty of the same crime in 1949.

 Ventura seeks the reversal of the ruling of CFI Rizal contending, inter alia, that he was not engaged in the
practice of medicine because he was only practicing drugless healing. He also theorized that to require any
person whose business is merely to stimulate by mechanical means the nerves of the body to undergo many
years of study in medical schools, take-up obstetrics, general surgery, gynecology, bacteriology and many
other sciences, is a curtailment of the exercise of one’s calling, a violation of the constitutional principle that
all men have the right to life, liberty, and the pursuit of happiness and are entitled to the equal protection of
the law.

ISSUE: W/N Ventura can be convicted for illegal practice of medicine for engaging in drugless healing without a
license.
RULING:
YES. Treating human ailments by means of drugless healing without the required license constitutes illegal practice
of medicine.

The practice of physiotherapy by massage through physical devices is allowed only if prescribed by a duly-registered
physician or if the application is limited to a physical or muscular development. In this case, Ventura diagnoses
patients on his own and even performs the said therapy to a wide range of areas of the body. This constitutes illegal
practice of medicine because he was doing it without the proper license.

RULING
CFI Rizal decision appealed from is hereby AFFIRMED in all parts and respects.