35) PRIVATE HOSPITALS V. MEDIALDEA, G.R. NO.

234448 (2018)
TIJAM, J.:
TOPIC: Proper Party
DOCTRINE: A party is allowed to raise a constitutional question when: a) he can show that he will
personally suffer some actual or threatened injury because of the allegedly illegal conduct of government;
b) the injury is fairly traceable to the challenged action; and c) Injury is likely to be redressed by a
favorable action. The exceptions to the rule on legal standing are a) over breadth doctrine; b) taxpayer
suits; c) third party standing; and d) doctrine of transcendental importance.
FACTS:

 RA 110932 was enacted making it unlawful to request, solicit, demand or accept deposit or
advance payment as a prerequisite not only for confinement or medical treatment but also for
administering basic emergency case.
 Petitioners seeks to strike down as unconstitutional RA 10932 for being unduly oppressive and
thus in violation of substantive due process.
ISSUE:
WON Petitioner has legal standing.
HELD:
No, petitioner has no legal standing. An association, like petitioner has no legal standing to file the
present case. Legal standing is one of the requisites for the exercise of power of judicial review. Legal
standing is defined as 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. As a rule, a party is
allowed to raise a constitutional question when: a) he can show that he will personally suffer some actual
or threatened injury because of the allegedly illegal conduct of government; b) the injury is fairly
traceable to the challenged action; and c) Injury is likely to be redressed by a favorable action. Without
doubt, RA 10932 governs the conduct of hospitals, medical facilities, medical practitioners, and
employees inasmuch as the law imposes upon them certain obligations and imposes corresponding
sanctions in case of violation. However, petitioner itself is NOT a hospital, a medical facility, medical
practitioner or employee, but an association thereof. While juridical persons, like associations, are
endowed with capacity to sue or be sued, it must demonstrate substantial interest that it has sustained or
will sustain direct injury. In case of violation of RA 10932, the liability or direct injuries are not to the
petitioner association itself but to the member- hospital.
The exceptions to the rule on standing are:
a. Over breadth doctrine;
b. Taxpayer suits;
c. Third party standing; and
d. Doctrine of transcendental importance.
To fall under the third party exception, the association filing a case on behalf of its members must not
only show that it stands to suffer direct injury, but also that it has been duly authorized by its members to
represent them or sue in their behalf. Here, petitioner failed to demonstrate that ample authority had been
extended to it by its members to file this case. The attached Board Resolution and Secretary’s Certificate
did not authorize petitioner to file the necessary petition to question the constitutionality of the law before
any court. Therefore, petitioner cannot benefit from the third party exception to the requirement of locus
standi.