UERM Memorial Medical Center Resident Doctors' Union vs Laguesma Digest

UERM Memorial Medical Center Resident Doctor’s Union vs Laguesma Facts: The existence of an employer-employee relationship between the resident physicians of the University of the East Ramon Magsaysay Medical Center and the hospital became the crux of the matter in its petition for certification. The resident physicians formed a union called the UERMMC-Resident Doctors Union and filed the petition for certification so that it will be recognized as the exclusive bargaining agent of all the resident physicians in the hospital for purposes of collective bargaining. The petition for certification was dismissed by the Undersecretary, acting under the authority of the Secretary of Labor, on the ground that there exist no employer-employee relationship between the resident doctors and the hospital. Issue: WON resident doctors are employees of the hospital Ruling: The case reached the Supreme Court. Said the Court: It is clear that physicians undergo residency training in order to hone their skills and develop or improve their knowledge in a specialized medical field or discipline. Hence, residency is basically and simply a continuation of their medical course. However, they are not required or mandated under any law to further undergo a residence training program. Having passed the medical board examinations, they are already licensed physicians and could very well engage in the general practice of medicine. It is for the practice of highly specialized medical disciplines which necessitates further on-the-job training thereon. Viewed from this perspective, residency training clearly amounts to a pursuit of further education on a specific discipline. Thus, the relationship between the teaching/training hospital and the resident doctor is not one of employer-employee. The training/teaching hospital may simply be likened to a medical school/university, but in this instance, the emphasis is on the practical application and training of its students, the resident doctors."