Sei sulla pagina 1di 48

LAWS AFFECTING MENTAL HEALTH

IN PHILIPPINE SETTING:
A CRITIQUE ON CAMBRIS POSITION PAPER OPPOSING HOUSE BILL 5347,
DISCUSSION OF PHILIPPINE HEALTH INSURANCE COVERAGE AND OTHER
COMMENTS AFFECTING MENTAL HEALTH

Authored by
Naomi Therese F. Corpuz

TABLE OF CONTENTS

I. UNITED NATIONS CONVENTION ON THE RIGHTS OF PERSONS WITH


DISABILITIES (UN CRPD) & OTHER INTERNATIONAL AGREEMENTS ARE
NOT ABSOLUTE3
A. Treaties are not absolute as they are subject to
police power of the State..4
B. Legal Capacity cannot be given to the mentally
impaired on an equal basis with others at all times9
C. Cambri hates Psychiatrists and Psychiatric drugs that is purely
opinion-based..11
D. Other Comments on Cambris Position Paper..14
II. NEED FOR INSURANCE COVERAGE NOT ONLY FOR THE ACUTE BUT
ALSO FOR CHRONIC MENTAL ILLNESSES..17
III. COMMENTS ON LAWS AFFECTING MENTAL HEALTH...26
A. Republic Act 7277 (Magna Carta for Disabled
Persons)....26

B. The 20% Discount for PWDs....33


IV. BIBLIOGRAPHY..38

LAWS AFFECTING MENTAL HEALTH


IN PHILIPPINE SETTING:
A CRITIQUE ON CAMBRIS POSITION PAPER OPPOSING HOUSE BILL 5347,
DISCUSSION OF PHILIPPINE HEALTH INSURANCE COVERAGE AND OTHER
COMMENTS AFFECTING MENTAL HEALTH*

Naomi Therese F. Corpuz**

Speak for people who cannot speak for themselves.


Protect the rights of all who are helpless.
Proverbs 31: 8

To this day, the Philippines is one of the remaining "30%" States which
still have no mental health law.1 This is why until now, patients can languish in
psychiatric hospitals because there are no rules nor oversight mechanisms to
review their cases.2 By recognition of these facts, a House Bill known as HB
5347 was drafted through the sponsorship of legislators such as Rep. Leni
** Cite as Naomi Therese F. Corpuz, LAWS AFFECTING MENTAL HEALTH IN PHILIPPINE
SETTING: A critique on Cambris Position Paper Opposing House Bill 5347, Discussion of
Philippine Health Insurance Coverage And Other Comments Affecting Mental Health.
**** J.D., University of the Philippines College of Law (2015); A.B. Psychology, cum laude,
University of the Philippines (2013).
1 Interview with Dr. June Pagaduan-Lopez, practicing psychiatrist at Cardinal Santos Medical
Center, March 23, 2016.
2 Supra.
2

Robredo and Sen. Pia Cayetano during the Sixth Congress of 2015. The
drafted law in HB 5347 is entitled, The Philippine Mental Health Act of 2015. 3
Although this bill was made, it has received criticisms such that it is allegedly
non-compliant with International Human Rights Conventions. The question is,
Are International Human Rights Conventions absolute? For if they are not
absolute, HB 5347 does not need to comply to these International Conventions
especially if such Conventions have loopholes and have received criticisms
themselves.

I. UNITED NATIONS CONVENTION ON THE RIGHTS OF


PERSONS WITH DISABILITIES (UN CRPD) & OTHER
INTERNATIONAL AGREEMENTS ARE NOT ABSOLUTE.
The relation of international law vis-a-vis municipal law was expressed in
Philip Morris, Inc. v. Court of Appeals, to wit:
xxx Withal, the fact that international law has been made part of the
law of the land does not by any means imply the primacy of
international law over national law in the municipal sphere. Under the
doctrine of incorporation as applied in most countries, rules of
international law are given a standing equal, not superior, to
national legislation.4 (Emphases mine)

This means that even if the Philippines is a signatory of an international law, it


does not necessarily mean that it is binding when there are national laws that
run contrary to it. This makes the position paper of Janice Marie Cambri 5
without merit where she stated in part:
We, the users/survivors of psychiatry and persons with psychosocial
disabilities, are opposing the Mental Health Bills filed in both Houses
of Congress due to the presence of provisions that contravene

3 Interview with Dr. Eduardo Tolentino, Past President of Philippine Psychiatric Association

(PPA), March 23, 2016.


4 cited in Lim v. Executive Secretary, 380 SCRA 739 (2002)
5 Cambri, Janice Marie, M.A., Founder of Transforming Communities for Inclusion of Persons
with Psychosocial Disabilities-Philippines (TCI-Phil) and wrote a position paper entitled, NO
TO MENTAL HEALTH LAWS THAT ARE NON-COMPLIANT WITH INTERNATIONAL HUMAN
RIGHTS CONVENTIONS.
3

international human rights standards such as the UN Convention on


the Rights of Persons with Disabilities (UNCRPD), the International
Covenant on Civil and Political Rights (ICCPR), and the Convention
against Torture and Other Cruel, Inhuman or Degrading Treatment or
Punishment. The Philippines signed, adopted, and/or acceded to all
these treaties. (Emphases mine).

To reiterate the last sentence which states, The Philippines signed, adopted
and/or acceded to all these treties, is misleading for it is non sequitur that the
Philippines will absolutely without exceptions will accede to all these treaties.
Cambri tends to forget that there are Philippine Jurisprudence where the
Supreme Court provides, among others, Lim v. Executive Secretary6 which
states:
From the perspective of public international law, a treaty is favored over
a municipal law pursuant to the principle of pacta sunt servanda.
Hence, [e]very treay in force is binding upon the parties to it and must
be performed by them in good faith. Further, a party to a treaty is not
allowed to invoke the provisions of its internal law as justification of its
failure to perform a treaty.
Our Constitution espouses the opposing view.
jurisdiction as stated in section 5 of Article VIII:

Witness our

The Supreme Court shall have the following powers


(2) Review, revise, reverse, modify, or affirm on appeal or certiorari, as
the law or the Rules of Court may provide, final judgements and order
of lower courts in:
(A) All cases in which the constitutionality or validity of any treaty,
international or executive agreement, law, presidential decree,
proclamation, order, instruction, ordinance, or regulation is in
question.
xxx xxx

xxx

xxx

In Inchong v. Hernandez, we ruled that the provisions of a


treaty are always subject to qualification or amendment by a
subsequent law, or that is subject to the police power of the State.
(Emphases mine)

6 380 SCRA 739 (2002).


4

A. Treaties are not absolute as they are subject to police power


of the State.
Cambri, in her position paper says that in 2008, the Philippine
government adopted the UNCRPD. She says further that this instrument sets
the global standard for the inclusion and full and effective participation of
persons with disabilities.7 She says that in essence, an international treaty
signed by the government becomes part of the laws of the land. She says
further, the provisions in the UNCRPD simply need to be harmonized with our
domestic laws through legislations by abolishing or repealing laws that are not
compliant with the UNCRPD and incorporating its mandates in existing policies
and practices of all government agencies8
Cambri seems to ignore however, that treaties and/or international agreements
that the Philippines adopt, such as the UNCRPD, are not absolute and dont
automatically become part of the laws of the land in the exercise of the police
power of the State.
Police power is well-defined in Philippine Exporters of Service
Associations, Inc. v. Drilon:9
The concept of police power is well-established in this
jurisdiction. It has been defined as the "state authority to enact
legislation that may interfere with personal liberty or property in
order to promote the general welfare." As defined, it consists of (1)
an imposition of restraint upon liberty or property, (2) in order to
foster the common good. It is not capable of an exact definition but
has been, purposely, veiled in general terms to underscore its allcomprehensive embrace
"The police power of the State ... is a power coextensive with
self- protection, and it is not inaptly termed the "law of overwhelming
necessity." It may be said to be that inherent and plenary power in the
State which enables it to prohibit all things hurtful to the comfort,
safety, and welfare of society."
It constitutes an implied limitation on the Bill of Rights.
According to Fernando, it is "rooted in the conception that men in

7 Cambri, Supra Note 5


8 Id.
9G.R. No. 81958, June 30, 1988.
5

organizing the state and imposing upon its government limitations to


safeguard constitutional rights did not intend thereby to enable an
individual citizen or a group of citizens to obstruct unreasonably the
enactment of such salutary measures calculated to ensure communal
peace, safety, good order, and welfare." Significantly, the Bill of Rights
itself does not purport to be an absolute guaranty of individual rights
and liberties "Even liberty itself, the greatest of all rights, is not
unrestricted license to act according to one's will." It is subject to
the far more overriding demands and requirements of the greater
number. (Emphases mine).

This means that if a mentally ill person will hurt himself or others due to
his condition, the State has the power to restrict his liberty - that is for the
interest of the general welfare.
Cambri further criticizes mental health bills in her position paper which
she describes to even manipulate the laws to justify forced treatments during
psychiatric emergency which they define as:
Psychiatric emergencies are conditions which may present a serious
threat to the persons wellbeing and/or that of others requiring
immediate psychiatric interventions such as in cases of attempted
suicide, acute intoxication, severe depression, acute psychosis, or
violent behavior.

Cambris position is absurd to question the definition of psychiatric


emergencies since it is only logical to have psychiatric interventions when
there are conditions which may present a serious threat to the persons wellbeing and/or that of others. Restricting the liberty of the individual under
such conditions cannot even be described as inhumane as the intervention is
medical and would even be beneficial to the person afflicted with the condition.
Freeman and colleagues10 explains this and even criticized the general
comment on UNCRPD and Article 12 in a Lancet Psychiatry Journal in 2015,
which states in part:
The UN CRPD and General Comment on Article 12

10 Melvyn Colyn Freeman et.al., Reversing hard won victories in the name of human rights: a
critique of the General Comment on Article 12 of the UN Convention on the Rights of Persons
with Disabilities (Lancet Psychiatry 2015 Journal), Published Online on July 6, 2015.
Available at http://dx.doi.org/10.1016/ S2215-0366(15)00218-7 (Last visited: March 23,
2016).

The UN CRPD was adopted by the UN General Assembly in December,


2006, and entered into force in May, 2008. It was subsequently ratified
or acceded to by 152 nation States. At the time of writing (January,
2015), 30 States had signed but not ratified the Convention
Importantly, the likelihood of a person making a recovery to the point of
regaining capacity and therefore being able to give informed consent is
often diminished without treatment. In the example of psychosis, we
might be undermining the right to health to allow a person to stay in a
psychotic state and never allow them to get to a point of refusing or
accepting treatment in an informed manner. The question then
becomes whether involuntary treatment of a person with psychosis can
be given at least to the point at which sufficient recovery has been
made to make an informed decision. Even if the right to health is not
a sufficient justification to treat a person without consent, what if a
person with mental illness is a danger to self or to others? For
example, what if the person is hearing voices that tell him or her
to hurt themselves or another person? Should such a person
rather be left to harm himself or herself or others or to go to jail
rather than be admitted to hospital without their consent?
Despite agreeing fully with the argument that involuntary admissions
and compulsory treatment are often overused, and have historically
resulted in the rights of people being violated, we cannot accept that
doing away completely with involuntary admission and treatment
will promote the rights of persons with mental illness. (Emphases
mine).

Our own law in special proceedings for instance, particularly Rule 101 of
the Rules of Court establishes the procedure for having a person allegedly
insane committed to an institution.11 Cambri, however, cites Rule 101 of the
Rules of Court entitled Proceedings for Hospitalization of Insane Persons that
allows for involuntary institutionalization as non-compliant with Articles 12
and 14 of the UNCRPD12 but she did not discuss the contents and substance of
such Rule.
Under Rule 101 a petition for the commitment of a person to a hospital
or other place for the insane may be filed with the Court of First Instance (now
Regional Trial Court) of the province where the person alleged to be insane is
found.13 The petition shall be filed by the Director of Health (now Secretary of
Health) in all cases where, in his opinion, such commitment is for the public
11 Antonio Bautista, BASIC SPECIAL PROCEEDINGS (2004).
12 Cambri, Supra Npte 5
13 RULES OF COURT, Rule 101, Sec. 1.
7

welfare, or for the welfare of said person who, in his judgment, is insane
and such person or the one having charge of him is opposed to his being taken
to a hospital or other place for the insane. 14 Upon satisfactory proof, in open
court on the date fixed in the order, that the commitment applied for is for the
public welfare or for the welfare of the insane person, and that his
relatives are unable for any reason to take proper custody and care of
him, the court shall order his commitment to such hospital or other
place for the insane as may be recommended by the Director of Health. 15
When the lawmakers crafted this law, they reiterated in the provision that
institution of the insane individual is for the common welfare and for the
welfare of said person, and not violate the latters right in any manner. More
importantly it is the exercise of the police power of the State to protect the
person from harming himself and others. Cambri must know that no matter
how numerous her citations are in her position paper criticizing national laws
that restrict liberty of the insane, supported, among others, by Interim Report
of the Special Rapporteur on torture and other cruel, inhuman, inhuman or
degrading treatment or punishment (2008) and Report of the Special Rapporteur
on torture and other cruel, inhuman or degrading treatment or punishment (2013)
of the UN General Assembly, such reports can never supersede the police
power of the State.
Police power cannot be contested according to
jurisprudence. The case of Lao H. Inchong vs. Jaime Hernandez et al.,16
emphasized that police power may not be curtailed or surrendered by any
treaty or any other conventional agreement.
The CRPD says that the existence of a disability shall in no case justify
a deprivation of liberty. Freeman and colleagues 17 say that this is an
important principle that deserves support, particularly as mental disability has
historically been used as justification to remove people from their communities
and restrict them to institutions. They explain:
However, application of an absolute rule of not admitting a
person because of mental disability could in some circumstances
result in the long-term deprivation of libertypossibly in a prison
rather than a potentially much short(er)-term deprivation in a

14 Id.
15 Id., Rule 101, Sec. 3.
16 101 Phil.,1155 (1957)
17 Freeman, Supra Note 10
8

hospital. In several countries, in addition to being mentally ill, danger


to self or others is a precondition to admit a person without their
consent as an added protection against arbitrary or unnecessary
admission. This precondition is not valid in all countries. For example,
in Italian law it is not dangerousness that is the base for an
involuntary admission but the need for treatment. It is argued that
since dangerousness is not a disease, dangerousness should be a
police problem and is not a medical problem. The involuntary
admission is therefore based solely on the need for treatment. Yet
with or without a dangerousness requirement in law, in specific
circumstances of mental illness, by temporarily admitting a
person without their consent, longer-term deprivation of liberty
can be avoided. (Emphasis mine)

Thus, not restricting the liberty of the mentally ill in a hospital as


Cambri suggests, may even do more harm than good.
Similarly, Cambri says that the Insanity Defense plea in the Revised
Penal Code which exempts a person with psychosocial disability from criminal
liability and is directed to an automatic confinement in hospitals is also noncompliant with Articles 12 and 14 of the UNCRPD18.
However, Freeman and colleagues as a rebuttal, explain19:
In all domestic courts, to be found guilty of a serious crime
necessitates proving that one must have: (1) committed the crime, (2)
intended to commit the crime, and (3) known that what one was doing
was wrong at the time. These criteria are known as the MNaghten
Rules and, according to them, every person is presumed sane until
proven otherwise. The related notion of mens rea or guilty mind is
invoked in legal settings and involves various levels of guilt. Moreover,
most courts require the accused to be able to follow court proceedings
in order to be tried and sentenced. Failure to do this owing to mental
incapacity is usually reason to divert the accused. We argue that
without mens rea as a litmus test for culpability in a crime with
respect to mental state, society would effectively discriminate
against persons with mental illness and persons with mental
illness would be held to a higher standard than other persons.
Further problems arise if a person with mental illness is
jailed rather than diverted to mental health treatment. First,
treatment in prison, even if the prisoner accepted such treatment, is

18 Cambri, Supra Note 5


19 Freeman, Supra Note 10
9

likely to be less effective than treatment in a hospital setting because of


differences in staff expertise and environment. Second, the person
might be a victim of violence due to stigma and discrimination against
persons with mental disorders, and third, should the prisoner be
disruptive, the prison authorities would have little power to provide
medical assistance unless consent were given. In view of the
circumstances in most prisons, psychotic behaviour might bring
serious consequencesif not from the prison authorities, then from
other inmates. (Emphases mine)

Thus, Freeman and collegues are correct to argue that, convicting a


person who committed a crime as a result of serious mental illness and
sentencing them to prison rather than diverting them for treatment and
possible quick discharge is unlikely to be to their benefit.

B. Legal Capacity cannot be given to the mentally impaired on


an equal basis with others at all times.
Cambri emphasizes Article 12 Section 2 of the CRPD which says States
Parties shall recognize that persons with disabilities enjoy legal capacity on an
equal basis with others in all aspects of life. This provision which asks for the
repeal and/or amendments of domestic laws in the Philippines would result to
problems and would affect in a wide magnitude our national laws. Freeman
and colleagues explain20:
In April, 2014, the Committee on the Rights of Persons with
Disabilities, the UN entity assigned to monitor implementation of the
Convention, finalised a General Comment concerning Article 12 (and
related articles), in which prevailing concepts of mental and legal
capacity were summarily overturned. This interpretation departs from
previous intergovernmental agreements on human rights and earlier
WHO recommendations on mental health law. At the centre of much
of the controversy is the term legal capacity. Article 12 Section
2 of the CRPD says States Parties shall recognize that persons
with disabilities enjoy legal capacity on an equal basis with others
in all aspects of life. The Committee consequently asserts that
henceforth substituted decision-making, compulsory treatment,
involuntary admissions, and diversion from the criminal system
process on the grounds of mental disability (sometimes called the
insanity defence) should be abolished. The magnitude of the
changes now asked of countries is enormous, yet the implications
seem to have largely flown under the radar of most governments and

20 Freeman, Supra Note 10


10

the mental health sector.


In the introduction of the General Comment, the Committee states
...there has been a general failure to understand that the human
rights-based model of disability implies a shift from the substituted
decision- making paradigm to one that is based on supported
decision-making. This change in approach leads the Committee to
state that State Parties have an obligation to require all health and
medical professionals (including psychiatric professionals) to obtain
the free and informed consent of persons with disabilities before any
treatment and not to permit admission to hospital unless requested by
the user.
The General Comment defines mental capacity as the decisionmaking skills of a person and rejects prevailing medical conceptions
of mental capacity, stating that it is highly controversial and that
mental capacity is not, as is commonly presented, an objective,
scientific and naturally occurring phenomenon. The Committee
argues that mental capacity and legal capacity should not be
conflated, and that impaired decision-making skills should not be
justification for suspension of legal capacity.
We submit that the Committees interpretation and conclusions
are highly problematic. We fully agree that disability should never be
the sole reason for the suspension of a persons rights, and also that
in both the realms of health care and in court all persons should be
presumed to have both mental and legal capacity. We submit though
that where it is proven in a given case from thorough psychiatric
assessment that the person does not have decision-making capacity
in a particular domain (for example with respect to hospital
admission, treatment, or financial transactions), at a particular
time, that the initial legal presumption must also be reassessed.
In other words, legal capacity should always be assumed unless
evidence, which must include a range of principled and practical
checks and balances, proves the contrary. In such cases, safeguards
should be pro- portionate to the persons circumstances, and to how
far the measures affect the persons rights and interests. Additionally,
such measures should apply for the shortest time possible, and should
be subject to regular review by an independent or judicial body.
Informed consent
Informed consent for treatment or hospital admission is a vital ethical
health-care principle, and it should not be over- ridden without
stringent consideration and assessment. However, there are times
when informed consent is not possible because of the condition of
the person and must be superseded, particularly where life is at

11

risk. With respect to life-saving treatment, a person in a coma or


a person with severe infectious or neurological disease, for
example, might need treatment without his or her informed
consent. A universal presumption of legal capacity and the
primacy of supported decision-making therefore cannot be
absolute and exceptions have to be considered. This must apply to
both physical and mental health.
In our view, excluding any exemption to the presumption of legal
capacity due to mental impairment, and as a result not allowing a
person with severe mental illness or other impairment to have
their circumstance treated as exceptional, might in fact violate
his or her rights, and in some circumstances could result in harm
to self or to others. (Emphases mine).

People from India, Norway, Denmark, Germany, France, some Advocacy


Organisations and other State Parties infact have given opinions that support
substitute decision-making21:
In India, Pathare and colleagues found that 933% of service user
respondents acknowledged the need to be taken to a clinic or a
hospital to see a doctor during a period of decisional incapacity and
various warning signs were identified by the participants themselves
including unable to take decisions on my own, hitting my family or
pets, not interacting with anyone, and if I talk too much to myself.
Family members are also usually strong advocates of some form of
involuntary admission and treatment and are often the people who
make the applications for involuntary admission and treatment when
they fail to convince their family member that treatment is needed.
Further, some advocacy organisations submitted statements for
consideration by the Committee in finalising the General Comment
that raised the question of limited uses of involuntary treatment,
including the Swedish National Association for Social and Mental
Health (RSMH), the Norwegian Federation of Organizations of Disabled
Persons, and the Danish Institute for Human Rights. The Swedish
Association wrote: As stated in this and other contexts RSMH
firmly believe that supported decision-making in general is the
better option to accommodate and support the individuals rights
both under the convention and in a practical sense......There are
however, in our view, under some circumstances an unacceptable level
of risk for the individual with seriously diminished mental capacity in

21 Freeman, Supra Note 10


12

the exercise of full agency to the point of self-harm or the right to veto
necessary decisions when periculam in mora.
Several States Parties also submitted statements in support of
substituted
decision-making
in
limited
circumstances
for
consideration by the Committee in finalising the General Comment,
including Norway, Germany, Denmark, and France. Norways
statement reflected back to the interpretive declarations made by the
country at the time of ratification, reserving the right to withdraw legal
capacity and allow for compulsory care or treatment in limited
circumstances. Speaking of their initial declarations, Norway stated:
The existence of several declarations similar to the Norwegian
declarations, the state reports submitted to the Committee and recent
national legislation intended to implement the Convention, indicate a
general understanding among the States Parties that the Convention
allows for substitute decision-making, provided that such provisions
meet certain criteria and are subject to legal safeguards.
Germany reported in its statement, It seems therefore that the
Committees interpretation is not shared by the State Parties in
general; not even by a substantial minority.
Germany continued, While sharing the view that the provision of
support for persons with disabilities is the best possible way to help
them exercise their rights, Germany remains convinced that there are
situations in which persons with disabilities simply are not able to
make decisions even with the best support available. Therefore, while
representing a shift in focus from substitute decision-making to
supported decision- making, the Convention could not and in
Germanys view does not rule out the possibility of substitute decisionmaking in some cases.

C. Cambri hates Psychiatrists and Psychiatric drugs -- that is


purely opinion-based.
There are statements on Cambris position paper that are purely based
on opinions not supported by evidence. She explained, among others, that
families are primary stress oppressors22:
22 Cambri, Supra Note 5
13

Several private mental health facilities in the Philippines


continue to detain patients despite eligibility for release for
profiteering reasons in conspiracy with the families of the latter who
wish to pass the burden of care...
In many cases, families are primary stress oppressors and
oftentimes facilitate involuntary admission to mental facilities of a
person with mental illness. To further frustrate matters, those close to
us are not likely to offer as much support as they would if we had
cancer or even AIDS instead. As already mentioned, most mental
health professionals are ignorant of our human rights stated in
international laws and perpetuate old harmful practices. A lot of us
who sought assistance from medical professionals ended being further
violated, abused, and traumatized.

Families and friends are actually very important in alleviating the


sickness of a person, such as depression. A website called, Families for
depression awareness explains23:
Medical professionals often remark on how helpful family members
and friends can be in reporting changes in depressed patients'
symptoms and ensuring that patients consistently take their
prescribed medication.
Families need to work together in managing treatment, since mood
changes and behaviors affect the whole family, and many issues are
involved in treatment.

It also apparent in her position paper that Cambri hates psychiatrists


very much and does not believe in the effectiveness of psychiatric
medications.24 She even criticizes the DSM (Diagnostic Statistical Manual)
since, according to her, it lacks validity and it is not evidence-based.25
In the website of the American Psychiatric Association, the latest edition
of DSM-V is described as the product of more than 10 years of effort by
hundreds of international experts in all aspects of mental health. 26 Their
dedication and hard work have yielded an authoritative volume that defines
and classifies mental disorders in order to improve diagnoses, treatment, and
23 Helping Someone Manage Depression available at http://familyaware.org/help-someonewho-has-depression/ (Last visited March 31, 2016)
24 Cambri, Supra Note 5
25 Id.
26 DSM-5 at https://www.psychiatry.org/psychiatrists/practice/dsm/dsm-5. (Last visited
March 31, 2016)

14

research.27 It explains further that it is used by clinicians and researchers to


diagnose and classify mental disorders, the criteria are concise and explicit,
intended to facilitate an objective assessment of symptom presentations in a
variety of clinical settingsinpatient, outpatient, partial hospital, consultationliaison, clinical, private practice, and primary care. 28 Thus, DSM being a
product of more than 10 years of many international experts negates Cambris
claim -- that the diagnoses of psychiatric drugs using such DSM is highly
subjective.
Mental Disorders do exist with scientific basis. According to studies,
scientists have largely attributed it to the brains functioning. Most scientists
believe that mental illnesses result from problems with the communication
between neurons in the brain called neurotransmission 29 and chemical
compounds called neurotransmitters.
For instance the neurotransmitter
serotonin levels of those with depression are lower than normal individuals.
Apart from serotonin there could also be other changes in other
neurotransmitters in the brain.30 In schizophrenia, studies show that there
are
disruptions
in
neurotransmitters
dopamine,
glutamate
and
31
norepinephrine.
Scientists have also identified the risk factors that make one mentally
ill. Some of these are environmental, genetic and social factors. 32 These factors
may also combine and interact that lead to mental illness. Environmental
factors such as head injury, poor nutrition, and exposure to toxins (including
lead and tobacco smoke) can increase the likelihood of developing a mental
illness.33 Illnesses which most likely have a genetic component are autism,
ADHD or attention deficit disorder, bipolar disorder and schizophrenia.34
Mental Disorders can also be psychosomatic. Psychosomatic pertains
to physical ailments that are caused by or notably influenced by emotional
27 Id.
28 Id.
29Information about Mental Illness and the Brain, available at

http://science.education.nih.gov/supplements/nih5/mental/guide/info-mental-b.htm (Last
visited: November 26, 2012).
30Id.
31Id.
32Id.
33Id.
34Id.
15

factors,35 such factors that can be attributed to mental disorders. Dr. Jercyl
Leilani Demeterio says that mental disorders are as debilitating as any form of
illness affecting the persons ordinary daily activities, even relationships and
even results to, if not correlated with, physical illnesses such as heart diseases,
thyroidism, stroke, cancer and many others.36
Psychopharmacology on the other hand only proves further that mental
disorders have a connection with the brain. Psychopharmacology is the
scientific study of the actions of drugs and their effects on mood, sensation,
thinking, and behavior; this field studies a wide range of substances with
various types of psychoactive properties, focusing primarily on the chemical
interactions with the brain. 37 It is also defined as, the study of drug-induced
changes in mood, thinking, and behavior. These drugs may originate from
natural sources such as plants and animals, or from artificial sources such as
chemical syntheses in the laboratory. These drugs interact with particular
target sites or receptors found in the nervous system to induce widespread
changes in physiological or psychological functions.38
However, as aptly explained by Dr. Jercyl Leilani Demetetrio 39, it is a sad
state that despite studies and evidence that mental disorders are attributed to
brain function there are still many who do not believe that there is a
connection of emotions and feelings to the brain.

D. Other Comments on Cambris Position Paper.


Cambri40 noted in her position paper, where she cited the Youngblood
article for the Philippine Daily inquirer41 of the author of this paper which
states in part:
35Dictionary.com, available at http://dictionary.reference.com/browse/psychosomatic (Last

visited: November 26, 2012).


36Interview with Dr. Jercyl Leilani-Demeterio, Past-PPA President, former Professor of
Psychiatry of U.P. College of Medicine and current private practioner at Cardinal Medical
Santos Center, Mandaluyong City (August 6, 2011).
37Psychopharmacology From Wikipedia, the free encyclopedia at
http://en.wikipedia.org/wiki/Psychopharmacology (last visited May 17, 2012).
38Psychopharmacology, available at
http://www.sciencedaily.com/articles/p/psychopharmacology.htm (Last visited: November 26,
2012).
39Interview with Dr. Jercyl Leilani Demeterio, past Philippine Psychiatric Association
president, former professor of U.P. College of Medicine and current psychiatrist at Cardinal
Santos Medical Center, Quezon City (May 15, 2012).
40 Cambri, Supra note 5
16

In a 2011 survey, 90 out of the 95 psychiatrist respondents were not


familiar with the Magna Carta for PWDs (Corpuz 2013). These blunders
only go to show how alienated these doctors really are from the sector.

However the debate over this issue presented above by Cambri is already moot
and academic as this survey by the author of this paper was conducted in
2011 when since 2014, the Philippine Psychological Association (PPA) paved
the way in crafting a bill known as House Bill 5347. It is also incorrect for
Cambri to say that HB 5347, among others, is bereft of any genuine and
participatory agreement with organic and primary stakeholders who are the
users/survivors of psychiatry and persons with psychosocial disabilities. 42 The
Bill before it was finalized for submission to the legislators was subjected to two
conferences- a pre summit in September 2014 and the Healthy Mind Summit 2
of October 2014.43 The two were attended by various stakeholders - from
patients and family, to MH institutions, civil society organizations, media, the
PMHA, the PAP, the DOH, the CHR and interested private citizens.44 A WHO
representative was present and even praised the initiative as well as the draft
bill.45 There were 495 attendees (18 as individuals and rest represented
organizations) in the summit proper and over 100 in the pre summit. 46 Thus, it
cannot be said that the primary lobbyists are only psychiatrists as Cambri in
her position paper states.
Furthermore, Cambri criticizes further the psychiatrists of PPA by stating in
her position paper:
"It is safe to assume that legislators and even government employees
working at the CHR simply took the word of the psychiatrists who
peddled these bills to them. As evidence, when questioned as to why
the filing of the bill, a Chief of Staff of one of the bills coauthors,
admitted finding nothing wrong with the bill when the doctors led by
Dr. June Lopez presented the draft, did not conduct any further study
or consultation with the sector at all, and simply signed. Former
Gabriela Rep. Liza Maza also confirmed that the latter talked to the

41 Corpuz, Naomi Therese, Mentally Disabled but not crazy, Youngblood Article Published on

February 7, 2013 in the Philippine Daily Inquirer, available at


http://opinion.inquirer.net/46373/mentally-disabled-but-not-crazy#ixzz43e2Vs541
42 Cambri, Supra Note 5
43 Interview with Dr. June Pagaduan-Lopez at Supra Note 1 and with Dr. Eduardo Tolentino at
Supra Note 3.
44 Id.
45 Id.
46 Id.
17

militant political party, Makabayan for support of the bill. It is


remarkably ironic and terribly alarming that Filipino psychiatrist and
professor, Dr. June Pagaduan-Lopez, one of the twelve new members of
the UN Subcommittee on Prevention of Torture and Other Cruel,
Inhuman or Degrading....."

However, Dr. June Pagaduan-Lopez and and Dr. Eduardo Tolentino 47


defended the psychiatrists especially those who are members of the PPA and
said that this observation of Cambri is an insult to the minds of our legislators
and members of the CHR who guided them through the crafting of HB 5347,
especially Congresswoman Leni Robredo and Senator Pia Cayetano whose
offices have been actively engaged in assisting them in shepherding the Bill,
not as a final perfect one, but one which the public and Congress can further
"craft" to perfection.
Cambri also emphasized in her position paper that the primary lobbyists of the
mental health bills are psychiatrists in the Philippines. This is ironic and a
hypocritical statement since the UNCRPD which Cambris group adhere to is
bereft of clinical experts on the General Comment Committee of UNCRPD.
Freeman and colleagues found through their research, which states in part 48:
The question then becomes, why does the General Comment
Committees interpretation veer so sharply away from previous
intergovernmental agreements and from what is currently deemed best
medical practice? The answer possibly lies in two areas, first the
near-total absence of clinical experts on the Committee, and
second the limited consultation with users.
At inception, no members of the Committee had a clinical or
related background (medical, clinical psy- chology, or graduate
degree in social work). After the second election, one member of
the Committee had a medical degree, who served a 2-year term
and was not re-elected. At present, no members of the Committee
have a clinical background. It is this iteration of the Committee
that finalised the General Comment.
Bartlett writes when discussing Article 17 that members of the
medical profession were not involved in the negotiations of the
draft Convention. The omission of clinician voices seems to have
become a pattern in the later phases of interpreting and
implementing, as noted above with respect to the composition of the

47 Id.
48 Freeman, Supra Note 10
18

Committee.
The involvement of service users in drafting the CRPD and the General
Comment was prioritised and we fully agree with this principle. We
acknowledge that many mental health service users and organisations
advocating on their behalf feel strongly that involuntary admission and
treatment should be done away with and many such organisations
submitted statements to the Committee for consideration in finalising
the General Comment. (Emphases mine)

Freeman and colleagues thus suggested that the service user input was not
broad enough to represent a range of different service user views. Thus,
they further explained in their research that there are countries who are infact
in favor of involuntary admission and treatment:
In responding to a request from the South African Department of
Health on whether there should be involuntary admission and
treatment, the Gauteng Consumer Advocacy Movement (GCAM), a
large user group, said The GCAM is in favour of involuntary
admission...We acknowledge that there are times when we as mental
health care users relapse and become mentally unstable and therefore
not capable of acting in our own best interest, especially when it comes
to treatment and the various ways of obtaining the necessary
treatment, which may include involuntary admission. We also
acknowledge that at times some of us might become verbally or
physically abusive or threatening, and it is then the responsibility of
the State to protect those around us and protecting us from harming
ourselves (personal communication). The GCAM did a survey of
their members in 2013 and found that 99% felt that psychiatric
medication has resulted in improved mental health and improved
quality of life (personal communication).

Therefore it is not true that in all countries, involuntary admission and


treatment will lead to detrimental effects to the mentally ill patient but rather,
even improve every aspect of his life.
Questions now arise against Cambris position paper: Did she make
studies in the Philippines where statistics are provided showing involuntary
admission and treatment would result to deleterious effects to the psychiatric
patient/s? Are her claims against psychiatrists and psychiatric drugs supported
by evidence? The answer to this is a resounding no. All she gave in her position
paper are provisions in the UNCRPD and other International Human Rights
conventions and citations not specific to the Philippines. No specific study that
provides statistics in the Philippines where there is torture and cruelty in

19

involuntary admission and treatment support her claim. An anecdote by one


patient who alleges to have been brought to the rehabilitation center by force
was shared but one experience coming from such patient does not represent
the statistics of the general population of the mentally impaired. It is also
notable that her hatred against Filipino psychiatrists, mental health workers
and psychiatric medicines are purely opinion-based. Did she consult legal
professionals that can give incites on legal jurisprudence regarding international
agreements? Again, it is apparent that she is ignorant of Philippine legal
jurisprudence. No matter how numerous are her citations on International
laws, this cannot hold water as police power of the state can never be curtailed
by international agreements, even that by the United Nations.

II. NEED FOR INSURANCE COVERAGE NOT ONLY FOR THE


ACUTE BUT ALSO FOR CHRONIC MENTAL ILLNESSES
Insurance as defined in the Insurance Code of the Philippines is an
agreement whereby one undertakes for a consideration to indemnify another
against loss, damage, or liability arising from an unknown or contingent
event.49
Although this definition may sound business for some, which
objectively is for private insurance companies and corporations, it is legitimate
for it serves as protection where the risk insured against by the insured is
compensated by the insurer when this contingent event arises. One of the risks
highly insured is health.
Health insurance in the Philippines started with Philippine Medical Care
Act of 1969 (RA 6111) which was organized and implemented by the
Government Service Insurance System (GSIS) and Social Service Security
(SSS).50 To target the lower income and non-salaried populations, it later tiedup with Local Government Units (LGUs) and Health Maintenance Organizations
(HMOs).51 In the early 1990s studies were made for the need of social based
insurance.
Hence in 1995 under President Fidel Ramoss leadership, the
National Health Insurance of the Philippines was made into effect known as RA
49Pres. Dec. No. 1460, 2 (1978). This is the Insurance Code of the Philippines.
50MARIA OFELIA ALCANTARA, FINANCING HEALTH CARE: THE NATIONAL HEALTH

INSURANCE SYSTEM (eds. Ma. Luz Querubin & Sonia Rodriguez, BEYOND THE PHYSICAL:
THE STATE OF THE NATIONS MENTAL HEALTH REPORT) (2002).
51Meeting of Minds, available at http://www.medobserver.com/article.php?ArticleID=440 (last
visited May 17, 2012).
20

7875.
RA 7875 gave birth to Philhealth which became the driver in
implementing the first and only social based insurance in the Philippines.
In a benefit package of R.A. 7875 of 1995 which states:
SEC. 10. Benefit Package. - Subject to the limitations
specified in this Act and as may be determined by the
Corporation, the following categories of personal
health services granted to the member or his
dependents as medically necessary or appropriate,
shall include:
a) Inpatient hospital care:
1) room and board;
2) services of health care professionals;
3)
diagnostic,
laboratory,
and
other
medical
examination services;
4) use of surgical or medical equipment and facilities;
5) prescription drugs and biologicals; subject to the
limitations stated in Section 37 of this Act;
6) inpatient education packages;
b) Outpatient care:
1) services of health care professionals;
2)
diagnostic,
laboratory,
and
other
medical
examination services;
3) personal preventive services; and
4) prescription drugs and biologicals, subject to the
limitations described in Section 37 of this Act;
c) Emergency and transfer services; and
d) Such other health care services that the
Corporation shall determine to be appropriate and costeffective: Provided, That the Program, during its initial
phase of implementation, which shall not be more than
five (5) years, shall provide a basic minimum package of
benefits xxx. (Emphasis Supplied)
21

There has been no mandate of insurance given to the mentally-ill. Since


the first health insurance was created in 1969, there has been no insurance
given to any mental illness only until a circular was issued in 2010.
Figure 1.
RA
7875
National RA
7875
National
Health Insurance Act Health Insurance Act
1995
1995
(as amended by RA
9241)
SEC.
11.
Excluded
Personal
Health
Services The benefits
granted under this Act
shall
not
cover
expenses for the services
enumerated hereunder
except
when
the
Corporation,
after
actuarial
studies,
recommends
their
inclusion subject to the
approval of the Board:
a)
non-prescription
drugs and devices;
b)
out-patient
psychotherapy
and
counselling for mental
disorders;
c) drug and alcohol
abuse or dependency
treatment;
d) cosmetic surgery;

SEC.
11.
Excluded
Personal
Health
Services The benefits
granted under this Act
shall not cover expenses
for
the
services
enumErated hereunder
except
when
the
Corporation,
after
actuarial
studies,
recommends
their
inclusion subject to the
approval of the Board:
a)
non-prescription
drugs
and devices;
b) alcohol abuse or
dependency treatment;
d) cosmetic surgery;
e) optometric services;
f) fifth and subsequent
normal
obstetrical
deliveries; and

PhilHealth Circular No.


09-2010

Coverage
Rules
of
Psychiatric Conditions
Requiring Admission
In order to facilitate
reimbursement
of
claims
on
confinements
for
psychiatric conditions,
the following rules are
hereby issued:
1. Claims for mental
and

behavioral

disorder shall be
compensable only
for patients with
acute attacks or
episodes
admitted for any
of

the

following

reasons:
a. When

22

e)
home
and
rehabilitation services;
f) optometric services;
g) normal obstetrical
delivery; and
h)
cost-ineffective
procedures which shall
be defined by the
Corporation.
xxx
(emphasis supplied)

g)
cost-ineffective
procedures which shall
be defined by the
Corporation.

aggressive

of

assaultive
behavior
presents
danger to self
or others;
b. When
patient

the
is

suicidal;
c. When

the

patient
becomes
manic

or

depressed and
there is gross
impairment in
judgement and
reality testing;
d. When
medication
side

effects

became
disabling

or

potentially life
threatening
(e.g.

severe

parkinsonism,
severe tardive
dyskinesia,

23

neuroleptic
malignant
syndrome);
e. For
special
medical
procedures
such

as

electric
convulsive
therapy. xxx

24

(emphasis
supplied)

Above are the provisions and the circular implemented and issued respectively
by the PhilHealth affecting mental illness in chronological order. The lack of
insurance coverage prior PhilHealth Circular No. 09-2010 was made categorical
under sec. 11 of the National Health Insurance Act of 1995 (RA 7875):
SEC. 11. Excluded Personal Health Services The
benefits granted under this Act shall not cover
expenses for the services enumerated hereunder
except when the Corporation, after actuarial studies,
recommends their inclusion subject to the approval of
the Board: xxx
b) out-patient psychotherapy and counselling for
mental disorders;
RA 9241, The Act Amending the National Health Insurance in 2003
amended RA 7875, particularly the benefit b) out-patient psychotherapy and
counselling for mental disorders of section 11 as shown in the first column of
Figure 1 above. This benefit was removed (as shown in the second column of
Figure 1) as one of those excluded for personal benefits thus making it vague if
mental disorders are now covered by PhilHealth.
Although the present psychiatric conditions covered was made clear after
8 years when PhilHealth Circular No. 09-2010 was issued ,52 it is surprising
to know that out of 94 respondent- psychiatrists in a survey done by
random sampling nationwide in 2011, 51 of them (54.26% of the
respondents) did not know that such health insurance coverage for their
patients exists.53
This only goes to show that there is poor dissemination of information
by the PhilHealth to the people, especially psychiatrists the most important
health provider for the mentally disabled.
52Philhealth Circ. No. 09-2010. This is the Coverage Rules of Psychiatric Conditions Requiring
Admission (hereinafter PH Circular 09-10).
53Survey conducted by Naomi Therese F. Corpuz on Psychiatrist-Respondents of Philippine
Psychiatric Association, Inc. (PPA), at Dusit Thani Manila, Makati City (July 28-30, 2011).

25

Although some of the guiding principle and policies of National Health


Insurance of 1995 are health for all especially the poor, universality and
equity as provided in section 2:
SEC. 2. Declaration of Principles and Policies. Section
II, Article XIII of the 1987 Constitution of the Republic
of the Philippines declares that the State shall adopt
an integrated and comprehensive approach to
health development which shall endeavor to make
essential goods, health and other social services
available to all the people at affordable cost.
Priority of the needs of the underprivileged, sick,
elderly, disabled, women, and children shall be
recognized. Likewise, it shall be the policy of the State
to provide free medical care to paupers.
In the pursuit of a National Health Insurance Program,
this Act shall adopt the following guiding principles:
xxx
b) Universality The Program shall provide all
citizens with the mechanism to gain financial access
to health services, in combination with other
government health programs.
The National Health Insurance Program shall give the
highest priority to achieving covErage of the entire
population with at least a basic minimum
package of health insurance benefits;
c) Equity The Program shall provide for uniform
basic benefits. Access to care must be a function of
a persons health needs rather than his ability to
pay;xxx (emphasis supplied)

26

it can be gleaned that the PhilHealth insurance coverage for mental disorders
as issued in its PH Circular 09-10 is limited only to acute inpatient care (as
shown in the third column of Figure 1 above).54
Apart from being limited, PhilHealth did not operationally define what acute
is and how different it is from chronic. Thus, it can only be assumed that the
terms acute and chronic are understood in their laymans terms: acute for
short period attacks55 and chronic for persistent and long-lasting attacks.56
It is important to distinguish the two because it is only inpatients with
acute attacks or episodes are covered in the PH Circular 09-10. The Circular
merely gave five reasons where this acute inpatient care is limited to, which
are:
(a) when aggressive of assaultive
presents danger to self or others;

behavior

54Phil Health Circular No. 09-2010 states: Coverage Rules of Psychiatric


Conditions Requiring Admission
In order to facilitate reimbursement of claims on confinements for
psychiatric conditions, the following rules are hereby issued:
1 Claims
for
mental
and
behavioral

disorder

shall

be

compensable only for patients


with acute attacks or episodes
admitted for any of the following
reasons:
a) When aggressive of assaultive behavior presents danger to self or
others;
b) When the patient is suicidal;
c) When the patient becomes manic or depressed and there is gross
impairment in judgement and reality testing;
d) When medication side effects became disabling or potentially life
threatening (e.g. severe parkinsonism, severe tardive dyskinesia,
neuroleptic malignant syndrome);
e) For special medical procedures such as electric convulsive
therapy.xxx (Emphasis Supplied)

55 Acute (medicine), available at http://en.wikipedia.org/wiki/Acute_%28medicine%29 (Last


visited: January 18, 2013).
56Chronic (medicine), available at http://en.wikipedia.org/wiki/Chronic_%28medicine%29
(Last visited: January 18, 2013).

27

(b) when the patient is suicidal;


(c) when the patient becomes manic or depressed
and there is gross impairment in judgement and
reality testing;
(d) when medication side effects became disabling
or potentially life threatening (e.g. severe
parkinsonism,
severe
tardive
dyskinesia,
neuroleptic malignant syndrome);
(e) for special medical procedures such as electric
convulsive therapy.(Emphases Supplied)
This means that even if a mentally-ill patient is confined for acute (short
period) attacks, but for reasons that do not fall under the five conditions above,
he or she will not be covered by PhilHealth insurance. According to Dr. Israel
Francis Pargas57, patients confined with chronic (long-lasting) physical
illnesses such as leukemia or in need of dialysis for kidney failure are
covered by Philhealth when they are confined, same with mentally-ill
inpatients also confined falling under the acute attacks or episodeslimited
to the five conditions enumerated. This also means, persons with chronic
physical illnesses confined are covered by PhilHealth but not persons with
chronic mental illnesses. This is questionable. Why only confine insurance
with inpatient acute episodes limited to only 5 conditions but not mental
illnesses that can also be chronic? By this fact alone there is already a unfair
and unjust treatment of PhilHealth by giving priority in insurance coverage to
other chronic ailments subject to confinement that are physical but not mental
illnesses.
Unfortunately these chronic mental illnesses are not in equal footing with
other chronic physical illnesses under PhilHealth Insurance. This then could
lead to more deleterious effects if inpatient chronic mental illnesses are not
covered by insurance while other forms of inpatient illnesses are - chronic or
acute.
Evidence shows that delays in treatments for mental disorders can lead
to increased morbidity and mortality and one of the determinants for this delay

57Interview with Dr. Israel Francis Pargas, Senior Manager for Benefits Development and
Research of PhilHealth, Pasig City (July 22, 2011).

28

is income and lack of health insurance coverage. 58 Less well known is the fact
that those with severe mental illness (SMI) are less likely to have health
insurance coverage of any kind.59 There have been reports that chronic
illnesses such as mental health problems, including depression and
schizophrenia, are among the 10 leading causes of disability worldwide. 60
According to a World Bank study, depression will become the second leading
cause of disability in 2010.61Clinical depression is a common mental disorder
that affects about 121 million people across the globe. 62 It is estimated that by
2020, clinical depression will be the second most leading cause of disability
worldwide second only to cardiovascular illness.63 If these are the cases, and
at the same time confinement of such chronic mental illnesses are not covered
by Philhealth, mentally-ill adults are more likely to be unemployed relative to
other adults.64 Multivariate studies of labor force outcomes have generally
found unemployment levels to be lower among persons with mental illness. 65
If they are unemployed, this would also result to non-eligibility for employer
sponsored insurance, the primary source of health care for elderly adults. 66
They also become ineligible to insurance disability benefits from GSIS or SSS if
they stop working for the government or a private employer respectively.
Although the basis of Philhealth in all its insurance coverage are
actuarial studies, it can be of help to widen the scope given to mentally-ill
patients if there are psychiatrists who can explain that early intervention
in treatment of mental illness lessens its reccurrence or even with greater
probability to be completely cured. Onset of mental illness occurs during
late adolescence or young adulthood especially the aged 25-34 years. 67 This
is the same age group that has the highest level of uninsurance; in part
because mental illness often begins during late adolescence or young
58Catherine Mclaughlin, Delays in Treatment in Mental Disorders and Health Insurance
Coverage, 39 Health Serv. Res. 221-224 (2004).
59Id.
60 Sol Jose Vanzi, Mental Health Problems: Psychiatrists Tap Social Science, available at
http://www.newsflash.org/2004/02/si/si001922.htm (last visited October 25, 2004).
61 Id.
62Cara Davis, 7 Ways to Ward off Clinical Depression, 3, at http://halogentv.com/articles/7ways-to-ward-off-clinical-depression/ (last visited: June 20, 2011).
63 Id.
64Catherine Mclaughlin, Delays in Treatment in Mental Disorders and Health Insurance
Coverage, 39 Health Serv. Res. 221-224 (2004).
65Id.
66Id.
67Id.
29

adulthood, it is more likely to have greater impact on educational attainment


and income than many other chronic conditions.68
Philhealth is not the only insurance corporation which limits its
insurance coverage to the mentally ill but also private insurance companies
such as HMOs (Health Maintenance Organizations). Although under the
National Insurance Code of the Philippines (RA 7875) these HMOs can be
accredited, to date, there has been no accredited HMO by PhilHealth.69
HMOs also do not provide any form of insurance, inpatient or outpatient, for the mentally disabled for the belief that mental disorders are
chronic and will consume too much of their funds. HMOs and other entities
must however be educated and informed that mental illnesses that are not
treated early can lead to worse conditions. If there is early intervention and
compliance to treatment for mental disorders, which can be done through
the support of an insurance coverage, there is shorter duration for the
improvement, and lesser dosages and treatment needed 70. If there is
decrease in dosages and maintenance treatment, then this will lead to decrease
in expenses, decrease in hospitalization and decrease for the need for
insurance benefits. There is also a possibility of completely not using such
insurance if the patient is completely cured. Early treatment of disorders like
depression, anxiety and drug and alcohol dependence can cut the risk that the
problem will persist past young adulthood, noted by the researchers, led by Dr.
Carlos Blanco of the New York State Psychiatric Institute at Columbia
University.71
However, there is a poor dissemination of information of the benefits and
privileges given to mentally ill patients covered by the Philippine Health
Insurance (PhilHealth). PhilHealth Insurance coverage for the mentally ill is
limited only to acute inpatient care which must fall under 5 conditions
enumerated by PH Circular 09-10. PhilHealth does not cover chronic mental
illnesses that must be subject also to confinement which only shows the
68Id.
69Interview with Dr. Israel Francis Pargas, supra note 57.
70Interview with Dr. Jercyl Leilani-Demeterio, Past-PPA President, former Professor of

Psychiatry of U.P. College of Medicine and current private practioner at Cardinal Medical
Santos Center, Mandaluyong City (August 6, 2011).
71Reuters, Mental health disorders common in young adults: survey, at http://www.abscbnnews.com/lifestyle/12/14/08/mental-health-disorders-common-young-adults-survey (last
visted May 19, 2012).
30

unjust treatment to mentally ill patients. This PH Circular 09-10 must be


amended by making known by the DOH, private sectors, mental health
professionals such as psychiatrists that mentally ill patients with chronic
illnesses subject to confinement must be covered by insurance of PhilHealth as
evidence shows that delays in treatments for mental disorders can lead to
increased morbidity and mortality and one of the determinants of this delay is
income and lack of health insurance coverage.

III. COMMENTS ON LAWS AFFECTING MENTAL HEALTH


Filipinos with mental illness are dicriminated against in various forms
where persons afflicted with other forms of illnesses are given more benefits
and privileges in legislative policies.

A. Republic Act 7277 (Magna Carta for Disabled Persons)


Republic Act 7277 was approved on March 24, 1992 entitled, An Act
Providing for the Rehabilitation, Self-Development and Self Reliance of Disabled
Persons And Their Integration Into The Mainstream Of Society And For Other
Purposes. This is otherwise known as the Magna Carta for Disabled Persons
which provides rights and privileges of disabled persons under its Title II which
are Equal Opportunity for Employment, Access to Quality Education, National
Health Program, Auxiliary Social Services, Telecommunications and Accessibility.
Although these six are listed in the law with comprehensive descriptions and
how they are adopted, people with mental disability are marginalized in the real
scenario and other people with illnesses are given more benefits, though not
apparent.
Section 5 of Title II states:
Section 5. Equal opportunity for employment. No
disabled person shall be denied access to opportunities
for suitable employment. A qualified disabled
employee shall be subject to the same terms and
conditions of employment and the same compensation,
privileges, benefits, fringe benefits, incentives or
allowances as a qualified able bodied person.

31

Five per cent of all casual, emergency and contractual


positions in the Departments of Social Welfare and
Development, Health, Education, Culture and Sports,
and other government agencies, offices or corporations
engaged in social development shall be reserved for
disabled persons.(Emphases Supplied).
As mentioned above, A qualified disabled employee shall be subject to
the same terms and conditions of employment and the same compensation,
privileges, benefits, fringe benefits, incentives or allowances as a qualified able
bodied person. Persons with physical disabilities could easily fit the term
qualified disabled employee but not for the mentally disabled. In Chapter VI
of Title II of R.A. 7277 Section 25, it implements Batasang Pambansa 344,
which states:
Sec. 25. Barrier-Free Environment. The State shall
ensure the attainment of a barrier-free environment
that will enable disabled persons to have access in
public and private buildings and establishments
and such other places mentioned in Batas
Pambansa Bilang 344, otherwise known as the
"Accessibility Law.
The national and local governments shall allocate
funds for the provision of architectural facilities or
structural features for disabled persons in government
buildings and facilities.(Emphases Supplied).
Batasang Pambansa 344, Section 1 states:

Section 1. In order to promote the realization of the


rights of disabled persons to participate fully in the
social life and the development of the societies in which
they live and the enjoyment of the opportunities
available to other citizens, no license or permit for the
construction, repair or renovation of public and private
buildings for public use. Educational institutions,

32

airports, sports and recreation centers and complexes,


shopping centers or establishments, public parking
places, work-places, public utilities, shall be granted or
issued unless the owner or operator thereof shall
install and incorporate in such building,
establishment, institution or public utility, such
architectural facilities or structural features as
shall reasonably enhance the mobility of disabled
persons such as sidewalks, ramps, railings and
the like. If feasible, all such existing buildings,
institutions, establishments, or public utilities to be
constructed or established for which licenses or permits
had already been issued may comply with the
requirements of this law: Provided, further, That in case
of government buildings, street and highways, the
Ministry of Public Works and Highways shall see to it
that the same shall be provided with architectural
facilities or structural features for disabled
persons. In the case of the parking place of any of the
above institutions, buildings, or establishment, or
public utilities, the owner or operator shall reserve
sufficient and suitable space for the use of disabled
persons. (Emphases Supplied)
Again, notice the term disabled persons is used in the above-quoted
provision but the cited law only benefits the physically disabled but not
persons afflicted with mental illnesses.
Apart from this there are still discriminations against mentally ill
patients particulary in employment and education.
Overseas contract workers for instance, prior to departure, must undergo
neuropsychiatric screening and those found with symptoms of mental distress
and symptoms are not certified to leave for overseas employment.72 Any
reapplication must be accompanied by psychiatric clearance, according to a
noted psychiatrist Dr. Bernardo Conde of University of Santo Tomas.73 This
72Dr. Bernardo Conde, Philippines mental health country profile, International Review of
Psychiatry, 166 (2004).
73Id.

33

regulation of the Department of Labor and Employment (DOLE) is unfair and a


total violation of social justice. With this regulation those who are afflicted
with mental disorders have no opportunity of having greener pastures abroad
to help their families but those with physical disabilities do since the latter do
not have the same kind of regulation. Yet, according to Dr. Jercyl Leilani
Demeterio, with proper treatment or psycho-therapy and medication, workers
with mental illnesses can function as normal individuals. 74 If this is the case
why does the DOLE not accept them with the same regulation as normal
individuals?
One reason for this is poverty. Although the Magna Carta For Disabled
Persons in its policy, states that:
Sec. 2. Declaration of Policy The grant of the rights
and privileges for disabled persons shall be guided by
the following principles:
(a) Disabled persons are part of Philippine society, thus
the State shall give full support to the improvement of
the total well-being of disabled persons and their
integration into the mainstream of society. Toward
this end, the State shall adopt policies ensuring the
rehabilitation, self-development and self-reliance of
disabled persons. It shall develop their skills and
potentials to enable them to compete favorably for
available opportunities.
(b) Disabled persons have the same rights as other
people to take their proper place in society. They
should be able to live freely and as independently as
possible. This must be the concern of everyone the
family,
community
and
all
government
and
nongovernment organizations. Disabled persons' rights
must never be perceived as welfare services by the
Government.
(c) The rehabilitation of the disabled persons shall
be the concern of the Government in order to foster
74Interview with Dr. Jercyl Leilani Demeterio, Supra Note 36.
34

their capacity to attain a more meaningful, productive


and satisfying life. To reach out to a greater number of
disabled persons, the rehabilitation services and
benefits shall be expanded beyond the traditional
urban-based centers to community based Programs,
that will ensure full participation of different sectors as
supported by national and local government agencies.
xxx (Emphases Supplied).
Not all Filipinos afflicted with mental illnesses can afford to have the
maintainance treatment and medication. In the Philippines alone, a disability
survey done in 2000 by the National Statistics Office (NSO) found out that
mental illness was the third most common form of disability. 75 Prevalence rate
of mental disorders were 88 per 100,000 populations and was highest among
the elderly group. This finding was supported by a more recent data from the
social weather survey commissioned by the Department of Health (DOH) in
2004. 76 It revealed that 0.7% of the total household have a family member
afflicted with mental disability.77
The policy of the Magna Carta cited above which states that (a) the State shall
give full support to the total well-being of the disabled, (b) Disabled persons have
the same rights as other people to take their proper place in society, (c) The
rehabilitation of the disabled persons shall be the concern of the Government in
order to foster their capacity to attain a more meaningful, productive and
satisfying life, are not fully enforced because of the miniscule budget alloted by
the Government to mental health.

Figure 2.78

75Interview with Mr. Nelson Mendoza, National Program Coordinator, National Mental Health

Program and Degenerative Disease Office, Department of Health, Philippines (March 30, 2012).
76Id.
77Id.
78Id.
35

The Philippine Government only gave 5% of its DOH budget to the National
Mental Health Program where only 5% of which are for health care
expenditures by the government health department directed towards mental
health. Of all expenditures on mental health, 95% are spent on the
operation, maintenance and salary of the personnel of mental hospitals.
The percentage of the population that has free access to psychotropic
medication is unknown.79 For those that pay out of pocket, the cost of
antipsychotic medication is 0.46% and antidepressant medication is 11.4% of
the minimum daily wage.80
There is also a scarce resource of Mental Health Workers.
conducted by World Health Organization in 2007:
Figure 3.
# of Mental
Health Workers per 100,000 pop
Psychiatrists*
412
0.42
Nurses

769

Psychologists

119

0.14

Social Workers

74

0.08

Occupational Therapists

72

0.08

Others

1,372

In a study

0.91

1.62

*237 (58%) of the Psychiatrists practice in the NCR


79Id.
80Id.
36

Out of 412 Psychiatrists in the Philippines, a majority of 237 of them are


based in the National Capital Region, making medical treatment from health
therapists out of reach to patients from provinces and far-flung barrios. Apart
from this, The majority of mental health facilities are still located in the
National Capital Region.81 Hence, access to mental health facilities is uneven
across the country, favoring those living near the main cities.82
In education on the other hand, a student may also suffer from schizophrenia,
ADHD (Attention Deficit Disorder), bipolar disorder, clinical depression and
anxiety disorders among others.83
A student with a mental disorder must be given considerations similar to
students with physical disabilities. If railings and ramps are built for students
with physical handicap, is there no special treatment that can be given to
mentally ill students?
Some authorities, particularly professors and
instructors find this questionable since most have the impression that mental
disorders are not life-threatening but in reality, they are as debilitating as any
form of illness that can even lead to death. In a World Health Organization
Report of 2007, more than 150 million people suffer from depression at any
point in time and nearly 1 million commit suicide every year.84
Special considerations though are given to disabled students that are
categorically stated in Section 12 of Title II of R.A. 7277:

Sec. 12. Access to Quality Education.


xxx
The State shall take into consideration the
special requirements of disabled persons in the
formulation of educational policies and Programs. It
shall encourage learning institutions to take into
account the special needs of disabled persons with
respect to the use of school facilities, class schedules,
physical education requirements, and other pertinent
consideration.
81Interview with Mr. Nelson Mendoza, Supra Note 75
82Id.
83Interview with Dr. Jercyl Leilani Demeterio, Supra Note 36.
84Department of Health Administrative Order No. 9 (2007).
37

The State shall also promote the provision by learning


institutions, especially higher learning institutions of
auxiliary services that will facilitate the learning
process for disabled persons. (Emphases Supplied).
What this pertinent consideration of the above-cited provision means
though is not specific. Legislators must specify the meaning of pertinent
consideration or at least the National Mental Health Program of the
Department of Health must make a separate Implementing Rule and
Regulation for Schools with mentally ill patients that will specifically describe
these pertinent considerations and mandate such schools to implement such
rules. Although Chapter II on Education of R.A. 7277 has a specific provision
on Special Education which states:
Section. 14. Special Education. The State shall
establish, maintain and support complete, adequate
and integrated system of special education for the
visually impaired, hearing impaired, mentally
retarded persons and other types of exceptional
children in all regions of the country. Toward this end,
the Department of Education, Culture and Sports shall
establish, special education classes in public schools in
cities, or municipalities. It shall also establish, where
viable, Braille and Record Libraries in provinces, cities
or municipalities. Xxx (Emphases Supplied).
and Section 17 for State Universities and Colleges:
Sec. 17. State Universities and Colleges. If viable
and needed, the State University or State College in
each region or province shall be responsible for (a) the
development of material appliances and technical aids
for disabled persons; (b) the development of training
materials for vocational rehabilitation and special
education instructions; (c) the research on special
problems, particularly of the visually-impaired, hearingimpaired, speech-impaired, and orthopedically-impaired
students, mentally retarded, and multi-handicapped
and others, and the elimination of social barriers and
38

discrimination against disabled persons; and (d)


inclusion of the Special Education for Disabled (SPED)
course in the curriculum. xxx (Emphases Supplied).
The provision makes use of the term mentally retarded which only includes
those pupils and students with subaverage intelligence and impaired adaptive
functioning.85 However mental retardation is not synonymous to mental
disability or mental illness. Mental Retardation is only one of the kinds of
mental illness. In fact there are persons with mental illness with superior
intelligence which is the total opposite of mentally retarded persons.86
Section 12 and Section 17 of Title II of Magna Carta for Disabled Persons are
discriminatory as it only provides privileges to the visually-impaired,
hearing-impaired, speech-impaired, orthopedically-impaired students,
mentally retarded, and multi-handicapped but there is no mention of
mentally disabled persons.
A sound suggestion was made by Carla Laforteza, a bipolar patient and a
physical therapist student of University of Santo Tomas with superior
intelligence. She said that the Government must create special schools for the
mentally ill87 those suffering not only of mental retardation but all types of
mental disorders, such as the common major illness of clinical depression.
Though it is difficult to establish special schools for courses such as medicine
and law, a special class that is segregated can be created solely for them. The
schools can hire certified psychiatrists and clinical psychologists. These
schools and/or special classes can be regulated and monitored by these
certified psychiatrists and clinical psychologists to determine the veracity and
gravity of the illness of the student-patient from time to time and assess their
capacity to learn. From these assessments, school rules and regulations can
be adjusted accordingly and not prevent a student from becoming a doctor,
lawyer or inhibit them from finishing other courses they want to pursue.

B. The 20% Discount for PWDs.


85Mental Retardation, http://emedicine.medscape.com/article/1180709-overview (Last visited:
January 14, 2013).
86Interview with Dr. Jercyl Leilani Demeterio, Supra Note 36
87Interview with Carla Laforteza, Physical Therapist Student of University of Santo Tomas
(November 13, 2012).

39

During the term of former President Gloria Macapagal Arroyo, Republic Act No.
9422 was enacted entitled as, An Act Amending Republic Act No. 7277,
Otherwise known as the Magna Carta for Persons with Disability as Amended,
and For Other Purposes Granting Additional Privileges and Incentives and
Prohibitions on Verbal, Non-Verbal Ridicule and Vilification Against Persons
with Disability. It is the objective of Republic Act No. 9442 to provide persons
with disability, the opportunity to participate fully into the mainstream of
society by granting them at least twenty percent (20%) discount in all basic
services. Section 1 of R.A. 9422 states:

SECTION 1. A new chapter, to be denominated as


"Chapter 8. Other Privileges and Incentives" is hereby
added to Title Two of Republic Act No. 7277, otherwise
known as the "Magna Carta for Disabled Persons", with
new Sections 32 and 33, to read as follows:
"CHAPTER 8. Other Privileges and Incentives
"SEC. 32. Persons with disability shall be entitled to the
following:
(a) At least twenty percent (20%) discount from all
establishments relative to the utilization of all services
in hotels and similar lodging establishments;
restaurants and recreation centers for the exclusive use
or enjoyment of persons with disability;
(b) A minimum of twenty percent (20%) discount on
admission fees charged by the theaters, cinema houses,
concert halls, circuses, carnivals and other similar
places of culture, leisure and amusement for the
exclusive use or enjoyment of persons with disability;
(c) At least twenty percent (20%) discount for the
purchase of medicines in all drugstores for the exclusive
use or enjoyment of persons with disability;
(d) At least twenty percent (20%) discount on
medical and dental services including diagnostic and
40

laboratory fees such as, but not limited to x-rays,


computerized tomography scans and blood tests, in all
government facilities, subject to guidelines to be issued
by the Department of Health (DOH), in coordination with
the
Philippine
Health
Insurance
Corporation
(PHILHEALTH);
(e) At least twenty percent (20%) discount on
medical and dental services including diagnostic and
laboratory fees, and professional fees of attending
doctors in all private hospitals and medical facilities, in
accordance with the rules and regulations to be issued
by the DOH, in coordination with the PHILHEALTH;
(f) At least twenty percent (20%) discount on fare for
domestic air and sea travel for the exclusive use or
enjoyment of persons with disability;
(g) At least twenty percent (20%) discount in public
Railways, skyways and bus fare for the exclusive use
and enjoyment of persons with disability;
Xxx(Emphases Supplied).
Under the law above, there are seven (7) types of basic services where persons
with disability can avail of atleast twenty percent (20%) discount.
The Department of Health adopted Administrative Order No. 9 Series
of 2011 (AO 09-11) entitled, Guidelines to Implement the Provisions of
Republic Act 9422 , Otherwise Known as An Act Amending Republic Act 7277,
otherwise known as Magna Carta for Persons, and for other Purposes, for the
provision of medical and related discounts and special privileges, which is an
order issued to support the Implementing Rules and Regulations of R.A. 9422.
Under this Order, the objective is to prescribe procedures and guidelines for the
implementation of the 20% discount in all health related services of Persons
with Disabilities (PWDs).
Although Republict Act 9422 is a big step in alleviating the financial
burden of PWDs, it is not without any disadvantage to persons with mental
illness. In relation to Republic Act 9422, to avail of the discount, a person
41

with disability must present his//her identification card issued by the National
Council on Disability Affairs (NCDA) or by the Local Government Units (LGUs)
where he/she resides.88 In addition, a purchase booklet issued by the LGUs to
persons with disabilities for free shall be presented every time a purchase of
medicine is made.89 Hence, although a mentally ill person can avail of a
discount in in public railways, skyways and bus fare or in purchasing
medicines there is an undeniable fact that there is a stigma attached to
persons with mental disorder while there is none to those who are suffering
from other illnesses. If an illness of a patient is not apparent, it is inevitable
that one of the assumptions of the persons seeing a PWD identification card is
that the patient who owns the card has a mental illness which he can possibly
identify as sirang ulo. Infact a mother of an autistic child said that she does
not want to avail of the PWD identification card because she doesnt want
anybody to identify that her daughter is, sirang ulo,90 though a mentally ill
patient with a PWD identification card is not insane or sirang ulo per se.
It is best if the legislators of R.A. 9422 and NCDA have thought of a different
term instead of Person With Disability (PWD) that will not identify the
patient, with non- apparent illness, in any way to be suffering from mental
illness. Persons With Discounts, Persons With Special Discounts are terms
that can be used for instance that will not identify the patient to be suffering
with any form of mental illness.
Also, in the experience of Perlas Reodica, when she bought the generic
medicine Clonazepam, a sedative for her anxiety disorder with her PWD
identification card in a known drugstore in Sta. Mesa, Manila, three of the
pharmacists told her, Drug addict ka ano? (You are a drug addict arent
you?).91 This experience only shows the discrimination and ridicule that the
PWD identification card can cause to a mentally ill patient. This also shows
that there is a need for a wider dissemination of information of R.A. 9422
particularly Prohibitions on Verbal, Non-verbal Ridicule and Vilification
Against Persons With Disability92 and its penal clause93.

88 National Council for Disability Affairs, Administrative Order No. 1, Series of 2008.
89Id.
90Interview with Mrs. Gene Lesaca, mother of a a 10 year old autistic child (October 7, 2012).
91 Interview with Perlas Reodica, patient with anxiety disorder (November 12, 2012).
92Rep. Act. No. 9244 2 (2007). This is known as the Amendment to R.A. 7277 otherwise
known as the Magna Carta for Disabled Persons of 2007 (hereinafter R.A. No. 9422)
933.

42

Another problem caused due to poor dissemination of information of R.A. 9422


is the discounted professional fees in private health facilities for in-patient and
outpatient medical, dental, and other health care professional services where
the corresponding physician or dentist must issue a corresponding official
receipt.
Figure 4. Survey on 95 Psychiatrist-Respondents94
Have you heard Do you think
of R.A. 7277 you
need
to
Magna Carta for know
more
Disabled
about
the
Persons
as Magna Carta for
amended
by Disabled
R.A. 9422?
Persons?
YES
58
90
NO
37
5

In a survey conducted in 2011, although 58 out of 95 psychiatrist-respondents


have heard of the Magna Carta for Disabled Persons, 90 of the 95 respondents
are ignorant of the contents of the said law. It is uncertain if this percentage of
ignorance holds true today. If it does, how can the patient avail of its
twenty percent discount from her doctor if her own physician is not aware
of the said law?
The downside however, if psychiatrists will learn of the twenty percent discount
that can be availed of by their patients under R.A. 9422, since there is no
ceiling price in their professional fees, they would be inclined to jack up their
prices.

94Survey conducted by Naomi Therese F. Corpuz, Supra Note 53.


43

BIBLIOGRAPHY
Laws
Department of Health Administrative Order No. 9 (2007).

44

National Council for Disability Affairs, Administrative Order No. 1, Series of 2008.
Phil Health Circular No. 09-2010
Presidential Decree No. 1460. This is the Insurance Code of the Philippines.
Republic Act 7277. This is the Magna Carta for Disabled Persons.
Republic Act. 9244. This is the Amendment to R.A. 7277 otherwise known as the Magna Carta
for Disabled Persons of 2007
Rules of Court

Books
Antonio Bautista, BASIC SPECIAL PROCEEDINGS (2004).
MARIA OFELIA ALCANTARA, FINANCING HEALTH CARE: THE NATIONAL HEALTH
INSURANCE SYSTEM (eds. Ma. Luz Querubin & Sonia Rodriguez, BEYOND THE PHYSICAL:
THE STATE OF THE NATIONS MENTAL HEALTH REPORT) (2002).

Cases
Inchong v. Hernandez, 101 Phil.,1155 (1957)
Lim v. Executive Secretary, 380 SCRA 739 (2002)
Philippine Exporters of Service Associations,

Inc. v. Drilon, G.R. No. 81958, June 30, 1988

Journal
Catherine Mclaughlin, Delays in Treatment in Mental Disorders and Health Insurance Coverage,
39 Health Serv. Res. 221-224 (2004).
Dr. Bernardo Conde, Philippines mental health country profile, International Review of
Psychiatry, 166 (2004).

Journal Online
Melvyn Colyn Freeman et.al., Reversing hard won victories in the name of human rights: a
critique of the General Comment on Article 12 of the UN Convention on the Rights of Persons

45

with Disabilities (Lancet Psychiatry 2015 Journal), Published Online on July 6, 2015.
Available at http://dx.doi.org/10.1016/ S2215-0366(15)00218-7 (Last visited: March 23,
2016).

Paper
Cambri, Janice Marie, M.A., Founder of Transforming Communities for Inclusion of Persons
with Psychosocial Disabilities-Philippines (TCI-Phil) and wrote a position paper entitled, NO
TO MENTAL HEALTH LAWS THAT ARE NON-COMPLIANT WITH INTERNATIONAL HUMAN
RIGHTS CONVENTIONS.

Websites
Acute (medicine), available at http://en.wikipedia.org/wiki/Acute_%28medicine%29 (Last
visited: January 18, 2013).
Chronic (medicine), available at http://en.wikipedia.org/wiki/Chronic_%28medicine%29 (Last
visited: January 18, 2013).
Cara Davis, 7 Ways to Ward off Clinical Depression, 3, at http://halogentv.com/articles/7ways-to-ward-off-clinical-depression/ (last visited: June 20, 2011).
Corpuz, Naomi Therese, Mentally Disabled but not crazy, available at
http://opinion.inquirer.net/46373/mentally-disabled-but-not-crazy#ixzz43e2Vs541 (Last
Visited April 1, 2016).
Dictionary.com, available at http://dictionary.reference.com/browse/psychosomatic (Last
visited: November 26, 2012).
DSM-5 at https://www.psychiatry.org/psychiatrists/practice/dsm/dsm-5. (Last visited March
31, 2016)
Helping Someone Manage Depression available at http://familyaware.org/help-someone-whohas-depression/ (Last visited March 31, 2016)
Information about Mental Illness and the Brain, available at
http://science.education.nih.gov/supplements/nih5/mental/guide/info-mental-b.htm (Last
visited: November 26, 2012).
Meeting of Minds, available at http://www.medobserver.com/article.php?ArticleID=440 (last
visited May 17, 2012).
Mental Retardation, http://emedicine.medscape.com/article/1180709-overview (Last visited:
January 14, 2013).

46

Psychopharmacology From Wikipedia, the free encyclopedia at


http://en.wikipedia.org/wiki/Psychopharmacology (last visited May 17, 2012).
Psychopharmacology, available at
http://www.sciencedaily.com/articles/p/psychopharmacology.htm (Last visited: November 26,
2012).
Sol Jose Vanzi, Mental Health Problems: Psychiatrists Tap Social Science, available at
http://www.newsflash.org/2004/02/si/si001922.htm (last visited October 25, 2004).

47

48

Potrebbero piacerti anche