CA denies US extradition of Filipino doctor in $3 million fraud

The decision of a Manila Regional Trial Court denying the United States government’s bid to extradite Filipino doctor Eric Uy Chan, accused of defrauding a California health care program of more than $3 million was affirmed by the Court of Appeals.

However, the appellate court disagreed with the RTC’s conclusion that Chan’s unchallenged evidence showed that the cases against him were politically motivated, as this was not a matter for the RTC to settle.

The CA said in its ruling dated 30 May 2025, “In rendering such a finding, the RTC effectively delved into the merits of the case and made a determination as to Chan’s innocence—an issue that lies beyond the proper scope and purpose of extradition proceedings.”

The American government, represented by the Philippine Department of Justice, asked the CA Eighth Division to reverse the local court’s ruling denying the petition for extradition, but the appellate court found no merit in its arguments.

The extradition of Chan was sought for him to stand trial for one felony complaint, and to be sentenced in another.

Chan’s cases involved conspiracy to commit a crime, grand theft, and healthcare fraud, and the presentation of false medical claims.

The accused had testified that his involvement was limited to providing financial support to the medical group in the case.

Chan argued that he was being harassed because he was perceived to be allied with President Ferdinand Marcos Sr., and the Central Intelligence Agency wanted him to testify with regard to the Marcos family’s bank accounts and assets in New York City

In July 2022, the Manila RTC ruled that the petition for extradition failed to show whether the period for prosecuting or executing punishment for the crimes against Chan had already lapsed.

The RTC said 7 to 8 years passed from the time the alleged offenses were committed before the petition for extradition was filed in January 2006. The US had the duty to show that the period between the initiation of the cases in the US and the filing of the extradition petition did not result in the dismissal of the charges due to prescription.

Represented by the DOJ, the US government contested the decision, saying that all the elements for extradition were present.

These include Chan’s admission to the allegations in one of his felony complaints and the presence of evidence such as the warrant of arrest, indictment, and judgment.

The CA in its decision agreed with the RTC and said the petition for extradition failed to allege the specific statutory provisions prescribing any time limitations on the execution of punishment for the offense as this is a requirement under the RP-US Extradition Treaty.

The decision penned by Associate Justice Eleuterio Bathan said,  “The provision of such critical information is indispensable, as it enables the requested state to undertake a prudent and comprehensive assessment as to whether the substantive and procedural requisites for extradition have been duly satisfied, with particular regard to the timeliness and ongoing enforceability of the criminal liability at issue".