Access & disclosure · NPC resolution
Parents’ access to a deceased patient’s medical records
Overview
The NPC upheld the parents’ right to their deceased daughter’s complete medical records and rejected the hospital’s reliance on PHIE privacy guidelines.
Facts and context
In Sps. NSP and EOP v. PSHCI, the hospital withheld records of the couple’s deceased daughter, MAP, invoking privilege over doctors’ orders and consent from other care providers.
Ruling
The 16 January 2025 decision found a violation of section 16(c), in relation to section 17, of the Data Privacy Act, ordered release, and awarded ₱50,000 each in nominal and moral damages. The 3 July 2025 resolution denied reconsideration: the PHIE guidelines did not curtail statutory access rights.
Practice implications
Parao Law practice guidance
For physicians
Refer requests to the hospital’s records office or privacy officer. Verify the requester’s entitlement and document the response; confidentiality alone does not justify refusal.
For lawyers
Identify the requester’s standing under section 17. Distinguish this access dispute from testimonial privilege in civil litigation; it does not authorize disclosure to every relative.