The Supreme Court held that a notarized affidavit recanting a previous statement holds more weight when determining the veracity of claims, especially when the initial statement was not notarized. This ruling emphasizes the importance of substantial justice over strict procedural adherence in administrative cases. It also clarifies the requirements for Special Powers of Attorney (SPA) in relation to verification and certification against forum shopping, ultimately ensuring that cases are decided on their merits rather than technicalities.

Zarsona’s Stand: Can a Notarized Affidavit Overturn a PhilHealth Decision?

The case of Zarsona Medical Clinic (ZMC) against the Philippine Health Insurance Corporation (Philhealth) began with a complaint against ZMC for allegedly violating Section 149 of the Revised Implementing Rules and Regulations of Republic Act No. 7875, also known as the National Health Insurance Act of 1995. The said section penalizes healthcare providers who extend a patient’s confinement period to claim more from Philhealth. The issue arose from a claim filed by ZMC for the confinement of Lorna M. Alestre, a member of the National Health Insurance Program (NHIP). Philhealth denied the claim, alleging that ZMC had extended Alestre’s confinement period. This denial was based on discrepancies between the claim form and Alestre’s initial statement (Salaysay).

ZMC defended itself by arguing that an employee had made an honest mistake when filling out the claim form, and that the hospital had only claimed for the actual two days of confinement. They also presented a subsequent Affidavit of Explanation from Alestre, recanting her earlier statement. The central question before the Supreme Court was whether the Court of Appeals erred in dismissing ZMC’s petition based on a technicality regarding the Special Power of Attorney (SPA) and whether Alestre’s recanted statement should be given weight in determining if ZMC indeed extended the period of confinement.

The Court of Appeals initially dismissed ZMC’s petition due to deficiencies in the SPA presented, specifically questioning whether it authorized the signatory to execute the verification and certification of non-forum shopping. ZMC insisted that the SPA authorized its representative to sign all necessary documents related to Philhealth claims. The Supreme Court acknowledged the defects in the SPA but emphasized that procedural rules should be liberally construed to achieve substantial justice. The court highlighted the importance of resolving the case on its merits, rather than dismissing it based on a technicality.

The Supreme Court discussed the requirements for verification and certification against forum shopping. Verification, intended to ensure the truthfulness of allegations, is considered a formal requirement that can be corrected or waived by the court. On the other hand, certification against forum shopping aims to prevent parties from pursuing simultaneous remedies in different courts or agencies. While typically not curable, the Court noted that exceptions exist under special circumstances or compelling reasons, or based on the principle of substantial compliance.

The Court referenced prior jurisprudence, such as Lim v. The Court of Appeals, Mindanao Station, reiterating that verification and certification against forum shopping are not jurisdictional requirements. The submission of an SPA authorizing an attorney-in-fact to sign these documents can be considered substantial compliance. In ZMC’s case, despite finding the SPA technically deficient, the Court emphasized that ZMC had acted in good faith by submitting what it believed to be a sufficient SPA.

While the SPA granted administrative powers, the Supreme Court took a more lenient stance considering the merits of the case. The court underscored that technicalities should not defeat the substantive rights of parties and that every litigant deserves a fair opportunity to have their case properly determined. Citing Sps. Wee v. Galvez, the Court reiterated that rules of procedure should not be interpreted with such literalness as to subvert their ultimate objective of achieving substantial justice as expeditiously as possible. Furthermore, quoting Alcantara v. Philippine Commercial and International Bank, the Court reminded that rules of procedure are mere tools aimed at facilitating the attainment of justice, rather than frustrating it.

Analyzing the charge against ZMC under Section 149 of the Revised Implementing Rules and Regulations of Republic Act No. 7875, the court delved into the evidence presented. This section outlines actions that constitute extending the period of confinement, such as: (a) increasing the actual confinement of any patient; (b) continuously charting entries in the Doctor’s Order, Nurse’s Notes and Observation despite actual discharge or absence of the patients; (c) using such other machinations that would result in the unnecessary extension of confinement. The penalties for such offenses include revocation of accreditation.

The Supreme Court diverged from the findings of Philhealth, choosing to give more credence to Alestre’s Affidavit, which recanted her earlier Salaysay. The Court provided several reasons for this decision. First, Alestre adequately explained why she initially misdeclared her dates of confinement, stating that she had to go back and forth between the hospital and her workplace. Second, the Court found her explanation of her whereabouts on the day in question credible, as she managed to visit both the hospital and her school. Third, ZMC had admitted to the error in indicating the confinement dates. Fourth, the Affidavit was notarized, thus carrying the presumption of regularity.

Drawing from Meneses v. Venturozo, the court emphasized that a notarized document carries the presumption of regularity and requires clear, convincing, and more than merely preponderant evidence to contradict it. Ultimately, the Supreme Court reversed Philhealth’s finding, concluding that ZMC was not guilty of extending the period of confinement. This decision hinged on the weight given to Alestre’s recanted affidavit, as well as the court’s preference for substantial justice over strict procedural compliance.

FAQs

What was the key issue in this case?	The key issue was whether the Court of Appeals erred in dismissing the petition based on a technicality regarding the Special Power of Attorney (SPA) and the weight to be given to a recanted affidavit in determining if Zarsona Medical Clinic (ZMC) extended a patient’s confinement period.
What is a Special Power of Attorney (SPA)?	A Special Power of Attorney is a legal document that authorizes a person (the attorney-in-fact) to act on behalf of another person (the principal) in specific matters. It must clearly define the scope of authority granted to the attorney-in-fact.
What is verification and certification against forum shopping?	Verification confirms the truthfulness of allegations in a pleading, while certification against forum shopping assures that a party is not simultaneously pursuing the same case in different courts or agencies. Both are procedural requirements aimed at ensuring the integrity of the legal process.
What is the significance of a notarized affidavit?	A notarized affidavit carries a presumption of regularity, meaning it is presumed to have been duly executed and to contain truthful statements. This presumption requires clear and convincing evidence to overcome.
What does “substantial compliance” mean in this context?	Substantial compliance means that the essential requirements of a rule have been met, even if there are minor deviations or technical defects. Courts may consider substantial compliance to prevent technicalities from defeating the ends of justice.
What was the basis for Philhealth’s initial denial of the claim?	Philhealth initially denied the claim based on discrepancies between the claim form submitted by ZMC and the initial statement (Salaysay) of the patient, Lorna M. Alestre, regarding her dates of confinement. Philhealth believed ZMC had extended the confinement period to claim more benefits.
Why did the Supreme Court side with Zarsona Medical Clinic despite the defective SPA?	The Supreme Court sided with ZMC due to the substantial merit of the case and the principle that procedural rules should be liberally construed to promote justice. The court found that ZMC had acted in good faith and that the patient’s recanted affidavit warranted a reversal of Philhealth’s decision.
What is the practical implication of this ruling?	This ruling reinforces the principle that substantial justice should prevail over strict procedural compliance, especially in administrative cases. It highlights the importance of considering all evidence, including recanted affidavits, in determining the truth and fairness of claims.

In conclusion, the Supreme Court’s decision in Zarsona Medical Clinic v. Philippine Health Insurance Corporation underscores the importance of balancing procedural rules with the pursuit of substantial justice. While adherence to rules is crucial, courts should exercise leniency and consider the merits of a case to ensure fairness and equity. This decision reaffirms that technicalities should not be used to defeat the substantive rights of parties, and that a just determination of a case should always be prioritized.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: ZARSONA MEDICAL CLINIC VS. PHILIPPINE HEALTH INSURANCE CORPORATION, G.R. No. 191225, October 13, 2014