Background

The case revolves around the practice of "referral decking" for medical examinations of overseas Filipino workers (OFWs). This system required OFWs to go through GAMCA for referral to specific clinics for health examinations. The DOH initially allowed this practice but later sought to prohibit it through administrative orders and eventually through legislation (RA 10022). When the DOH issued cease and desist orders against GAMCA to stop the referral decking system, GAMCA challenged this in court, leading to a legal battle over the validity of the prohibition and its implementation.

Facts

• 1. On March 8, 2001, DOH issued Administrative Order No. 5, Series of 2001 (AO 5-01) directing the decking or equal distribution of migrant workers among GAMCA member clinics.
• 2. Subsequent DOH issuances suspended and eventually terminated the referral decking system.
• 3. In 2010, Republic Act No. 10022 was enacted, amending RA 8042. Section 16 prohibited the referral decking system and monopolistic practices in OFW health examinations.
• 4. On August 23, 2010, DOH ordered GAMCA to cease and desist from implementing the referral decking system within 3 days.
• 5. GAMCA filed a petition for certiorari and prohibition with the RTC challenging the DOH order and the constitutionality of RA 10022 provisions.
• 6. The RTC ruled in favor of GAMCA, declaring the DOH orders null and void.

Arguments of the Petitioners

• 1. The RTC erred in giving due course to GAMCA's petition for certiorari and prohibition.
• 2. The DOH cease and desist orders were a valid exercise of police power.
• 3. The prohibition against the referral decking system does not violate principles of sovereign equality and independence.
• 4. The RTC had no jurisdiction to entertain GAMCA's petition.

Arguments of the Respondents

• 1. The DOH orders constitute an undue taking of property without due process.
• 2. The referral decking system is part of the GCC States' visa application procedure and cannot be interfered with by Philippine law.
• 3. Prohibiting the referral decking system violates the principle of sovereign equality and independence of states.
• 4. OFWs would suffer irreparable damage if the DOH orders were implemented, as GCC States would not issue visas without GAMCA's involvement.

Issues

• 1. Whether the RTC erred in giving due course to GAMCA's petition for certiorari and prohibition
• 2. Whether the DOH committed grave abuse of discretion in issuing the cease and desist orders
• 3. Whether the prohibition against the referral decking system violates principles of international law
• 4. Whether the RTC had jurisdiction over GAMCA's petition

Ruling

• 1. The RTC erred in giving due course to GAMCA's petition for certiorari and prohibition.
• 2. The DOH did not commit grave abuse of discretion in issuing the cease and desist orders.
• 3. The prohibition against the referral decking system does not violate principles of international law.
• 4. The RTC did not have jurisdiction over GAMCA's petition.

Rationale

• 1. The DOH cease and desist orders were quasi-judicial in nature and should have been challenged before the Court of Appeals, not the RTC.
• 2. GAMCA failed to exhaust administrative remedies before filing the petition.
• 3. The prohibition against the referral decking system is a valid exercise of police power to protect OFWs' welfare.
• 4. The principle of sovereign equality does not exempt GAMCA from complying with Philippine laws regulating medical clinics within the country.

Doctrines

• 1. Hierarchy of Courts - Petitions should be filed with the court of appropriate level and jurisdiction.
• 2. Exhaustion of Administrative Remedies - Parties must exhaust available administrative remedies before seeking judicial intervention.
• 3. Police Power - The state's authority to regulate private rights in the interest of public welfare.
• 4. Sovereign Immunity - The principle that a state cannot be sued without its consent, but does not extend to exemption from domestic laws.

Precedents Cited

• 1. Municipal Council of Lemery, Batangas v. Provincial Board of Batangas - Cited to explain the nature of quasi-judicial functions.
• 2. Republic of Indonesia v. Vinzon - Used to discuss the principle of sovereign immunity and its limitations.
• 3. Angara v. Electoral Commission - Referenced to explain the concept of judicial review.

Statutory and Constitutional Provisions

• 1. Article VIII, Section 1 of the 1987 Constitution - Judicial power and the expanded jurisdiction of the courts
• 2. Article II, Section 2 of the 1987 Constitution - Adoption of generally accepted principles of international law
• 3. Article VII, Section 21 of the 1987 Constitution - Treaty-making power of the President