Digest of the Case: People v.
Buenviaje
Facts:
Joвіта V. Buenviaje (defendant) was charged with violating the Medical
Act for practicing medicine without a license.
The defendant, a graduate of chiropractic from the American University
School of Chiropractic in Chicago, treated Regino Noble for ailments by
manipulating his head and body.
She advertised herself as a "doctor of chiropractic" using business
cards, newspaper ads, and signs on her office door, prefixing "Dra."
(short for "doctora") to her name.
The defendant admitted to these actions but argued that chiropractic
was not medicine and that she was not required to have a medical
license.
Issues:
1. Multiple Offenses: Whether the information charged more than one
offense: illegal practice of medicine and illegally representing oneself
as a doctor.
2. Chiropractic as Medicine: Whether chiropractic falls under the
definition of "practice of medicine" and requires a medical license.
3. Constitutional Rights: Whether requiring chiropractors to take the
medical board exam is unreasonable and violates constitutional rights
to life, liberty, and the pursuit of happiness.
4. Use of "Doctor" Title: Whether the prohibition against unauthorized
use of the title "doctor" applies to doctors of chiropractic.
5. Constitutionality of Act No. 3111: Whether Act No. 3111, amending
the Medical Act, is constitutional.
Ruling:
Multiple Offenses: The Supreme Court ruled that the information did
not charge multiple offenses. The Medical Act, as defined in the
Administrative Code, does not distinguish between illegal practice of
medicine and illegally advertising oneself as a doctor. Both are
violations of the same law with the same penalty.
Chiropractic as Medicine: The Court held that chiropractic falls
under the definition of "practice of medicine" as defined in the
Administrative Code. The statutory definition of "practice of medicine"
encompasses manipulations employed in chiropractic, overriding the
ordinary understanding of the term.
Constitutional Rights: The Court found no merit in the argument
that requiring chiropractors to take the medical board exam is
unreasonable or unconstitutional. The subjects covered in the exam
are necessary for proper diagnosis of diseases and fall within the
state's police power to ensure public health.
Use of "Doctor" Title: The Court ruled that the prohibition against
unauthorized use of the title "doctor" applies to doctors of chiropractic.
Since chiropractic is considered a form of medical practice,
representing oneself as a "doctor of chiropractic" is equivalent to
representing oneself as a "doctor of medicine."
Constitutionality of Act No. 3111: The Court upheld the
constitutionality of Act No. 3111, finding that its title adequately
expresses its subject matter and that it does not violate the rule
against multiple subjects in a single act.
Principles Discussed:
Statutory Interpretation: The Court emphasized the importance of
following the statutory definition of "practice of medicine" over the
ordinary understanding of the term.
Police Power: The Court upheld the state's right to regulate medical
practice through the exercise of its police power to protect public
health.
Constitutional Rights: The Court balanced the defendant's
constitutional rights with the state's interest in protecting public
health, finding that the requirements for practicing medicine are not
unreasonable.
Professional Regulation: The Court affirmed the importance of
professional regulation to ensure that only qualified individuals engage
in medical practice.
Conclusion:
The Court affirmed the defendant's conviction for violating the Medical Act,
finding that she practiced medicine without a license and illegally
represented herself as a doctor. The decision underscores the importance of
following the law and obtaining the necessary qualifications to practice
medicine, even in specialized fields like chiropractic.
