CENTRALIZED BAR OPERATIONS – ACADEMICS COMMITTEE 2022

FORMAT FOR CASE DIGEST:

1. Use Avenir font size 10 - JUSTIFIED

2. Try to contain your case digest in 1 to 2 pages
3. Portrait
4. For Ruling/Doctrine try to use the wordings of the Supreme Court as much as possible
5. BOLD the Title of the case 

TEMPLATE:
CASE NO. CASE TITLE

1 CASE TOPIC

GR No. XXXXXX , Date Ponente:

DOCTRINE

FACTS

ISSUE/S

RULING
FORMAT BASED ON ATTY SARAH’S LECTURE
 
TITLE
PHIL. REPORTS/SCRA/G.R. NO.
DATE
PONENTE
DOCTRINE: 
 
FACTS:
a. First Paragraph: Kind of Case, Parties; Dates (if necessary)
i. Know what type of case it is or the subject it falls into
ii. Who are the parties involved
a. Refrain from identifying the parties as Petitioner, Respondent, Complainant, etc.
throughout the case
b. Include the full name of the parties when first mentioned then write their shortened name
in a parenthesis, then a comma to identify whether they are the petitioner, respondent,
complainant, etc. The shortened name in the parenthesis will be used to indicate the
parties in the latter parts of the digest.
● Examples: 
o FIRST REFERENCE OF PARTIES: “Juan de la Cruz (de la Cruz),
complainant, filed a disbarment case against Attorney Juana Antonio
(Antonio), respondent, for violation of Canon 6 of the Code of
Professional Responsibility (CPR).”
o SUBSEQUENT REFERENCE OF PARTIES: “De la Cruz alleged that
Antonio was engaged in private practice of law while she was working as
Legal Officer V of the Manila Urban Settlements Office (MUSO). This
goes against Canon 6 of the CPR which pertains to lawyers in
government service in the discharge of their tasks.”
iii. Dates, only if necessary
b. Second Paragraph: Allegations of Petitioners/Appellants/ Those asking for relief.
c. Third Paragraph: Defenses of Defendants/Appellees/Those who were filed against
d. Fourth Paragraph: Procedural History (From the lower court/tribunal to the appellate court/tribunal to
Supreme Court).
 
ISSUE/S:
● It must end with a period and begins with a question that is not a whether or not
o Note that it must indicate the question of law to be decided, and not merely whether or not the
law is valid or if the defendant is liable or guilty.
● Ex. Was Antonio’s acts of private practice of law falls under the rule against conflict of interest.)
 
HOLDING/RULING/HELD:
● Use the ALAC methods as much as possible.
● Answer the question laid down in the issue.
o Yes, Antonio’s acts of private practice of law falls under the rule against conflict of interest.
 
 
SAMPLE:
CASE NO. Fortune Medicare, Inc vs. Amorin

1 INSURANCE LAW - Construction of an insurance contract

G.R. No. 195872  | March 12, 2014 Ponente:  Reyes, J.

DOCTRINE Any ambiguity in a contract whose terms are susceptible of different interpretations must be read
against the party who drafted it. A health care agreement is in the nature of non-life insurance,
which is primarily a contract of indemnity. Once the insured member incurs expense arising from
sickness, injury or other stipulated contingent, the health care provider must pay for the same to
the extent agreed under the contract.
FACTS
David Amorin, a permanent employee of House of Representatives, was a cardholder/member of
Fortune Medicare, Inc. where the terms of Amorin's medical coverage were provided in a
Corporate Health Care Program Contract executed between Fortune Care and the House of
Representatives.
 
During vacation, Amorin underwent an emergency appendectomy in Hawaii, incurring
professional and hospitalization expenses of US$7,242.35 and US$1,777.79. However, when he
attempted to recover the full amount, Fortune Care only allowed the reimbursement of P12,151.36
which would be the cost has the surgery was performed in an accredited hospital in Metro Manila.
Amorin accepted the amount but asked for the adjustments to cover the professional fees which he
had paid 80% of the approved standard charges based on "American standard" citing, Sec 3(b) Art
VI of the health care contract which provides that:
 
“… However, if the emergency confinement occurs in a foreign territory, Fortune Care
will be obligated to reimburse or pay eighty (80%) percent of the approved standard
charges which shall cover the hospitalization costs and professional fees…”
 
Fortune Care denied Amorin's request reasoning that the Health Care Contract did not cover
hospitalization costs and professional fees incurred in foreign countries, as the contract's operation
was confined to Philippines and its liability to Amorin was extinguished upon the acceptance of
the P12,151.36.
 
Amorin filed a complaint for breach of contract with damages but was dismissed by RTC Makati.
CA reversed the RTC decision on the grounds nothing under Art V of the Contract which
provided that the Philippine standard should be used even in the event of an emergency
confinement in a foreign territory and that Health Care Contract, being an insurance, should be
construed in favor of two interpretations and construction conferring coverage is to be adopted
and exclusionary clauses of doubtful import should be strictly construed against the provider.

ISSUE/S Was Fortune Care still liable for Amorin’s surgery based on his incurred expenses.

RULING YES, Fortune Care is still liable for Amorin’s surgery expenses. Since the Health Care Contract is
an contract of adhesion, the ambiguities in a contract are interpreted against the party that caused
the ambiguity. Any ambiguity in a contract whose terms are susceptible of different interpretations
must be read against the party who drafted it.
 
A health care agreement is in the nature of non-life insurance, which is primarily a contract of
indemnity. Once the insured member incurs expense arising from sickness, injury or other
stipulated contingent, the health care provider must pay for the same to the extent agreed under
the contract. Hence, Fortune Care's liability to Amorin should be based on the expenses for
actually incurred, and should not be limited by the amount that he would have incurred had his
emergency treatment been performed in an accredited hospital in the Philippines.
 
Based on the Health Care Contract, the possibility of emergency care in a foreign country was
contemplated. The contract recognized Fortune Care's liability for emergency treatments even in
foreign territories, it expressly limited its liability only to the percentage of hospitalization and
professional fees that must be paid or reimbursed was concerned, pegged at a mere 80% of the
approved standard charges.
 
The phrase "standard charges" in Sec 3 (B) of the contract should be contemplated as the
emergency care in non-accredited hospitals, declaring the standard in the determination of the
amount to be paid, without any reference to and regardless of the amounts that would have been
payable if the treatment was done by an affiliated physician or in an affiliated hospital. For
treatments in foreign territories, the only qualification was only as to the percentage, or 80% of
that payable for treatments performed in a non-accredited hospital.
 
In the absence of any qualifying word that clearly limited Fortune Care's liability to costs that are
applicable in the Philippines, the amount payable by Fortune Care should not be limited to the
cost of treatment in the Philippines, as to do so would result in the clear disadvantage of its
member.