THE Court of Appeals (CA) has affirmed the decision of a Manila regional trial court denying the extradition request by the United States involving a Filipino doctor who is wanted in California for a string of criminal cases, including health care fraud amounting to more than $3 million.
The request was anchored on the extradition treaty signed between the Philippines and US governments, which was signed in 1996.
In a 25-page decision, the CA Eight Division upheld the July 4, 2022 decision of the Manila Regional Trial Court Branch 33 which rejected the request for the extradition of Eric Uy Chan.
The decision was promulgated on May 30, 2025, with Associate Justice Eleuterio Bathan as the ponente.
Ferrer is a Filipino medical doctor and medical technologist who was employed at the Long Beach Medical Clinic in Long Beach, California.
Chan, according to the extradition request, is wanted so he can stand trial and be sentenced by the Superior Court in Los Angeles, Cali fornia on charges of conspiracy to commit a crime, grand theft, health care fraud, and presentation of false medical claims.
According to the charge sheet against Chan, he and his co-conspirators supposedly jointly owned and operated a medical clinic which allegedly defrauded California’s Medi-Cal program by receiving payments for false and fraudulent claims. They were arrested in 1998, but were allowed to post bail.
On November 1999, Chan voluntarily waived his rights to a trial and to remain silent, and entered a no contest plea to the charges, which, according to the records of the case, carried the same legal effect as a guilty plea to the 12 remaining charges against him.
Chan’s plea was not made pursuant to any agreement with the prosecutors, but Judge Jacquiline Connor found that he knowingly waived his constitutional rights, and thus, found him guilty of all the charges.
The court set the sentencing date to February 7, 2000.
However, Chan failed to appear for the sentencing date, prompting the court to issue a no-bail bench warrant for his arrest.
US authorities said that to date, Chan has not appeared for his sentencing.
An arrest warrant was also issued against Chan on January 21, 2000 in another felony case, where he and his co-conspirators are accused of theft in excess of $1 million and for presenting false claims to the Medi-Cal program, but he was not arrested and has never appeared in court.
One of his co-conspirators identified by the US authorities as Annilee Archangel Ferrer entered a no contest plea to the charges and was sentenced to five years in state prison.
Chan’s failure to appear in court for his sentencing prompted the US Department of Justice to seek his extradition from Manila.
In his defense, Chan, who testified that he is a licensed physician and holds the rank of colonel in the Armed Forces of the Philippines, denied the charges against him and said his only participation in the medical business venture was to provide financial support and that he had no participation in its management, daily operation, or billing process.
Chan also claimed that his troubles began when he and his family migrated to the US in 1991 after he was allegedly subjected to harassment and cases were filed against him supposedly due to his perceived allegiance to the administration of ousted dictator, Ferdinand Marcos Sr.
He added he was purportedly approached by the US Central Intelligence Agency sometime in 1994 through a man named Charles Bosworth and asked to testify regarding the Marcos family’s bank accounts and assets in New York and other parts in the US.
He said that after he denied the CIA’s request, the US government began a campaign of harassment against him, which eventually led to the closure of his businesses, including several medical clinics.
Ferrer also testified on his behalf, saying there is no basis for Chan’s extradition, adding she was forced to testify against him as the US government threatened her with imprisonment and deportation.
In 2022, the Manila RTC denied the US extradition request, saying the latter failed to demonstrate whether the period for prosecution of Chan had already tolled or lapsed, noting that 26 years have passed since the alleged offenses were committed.
“To allow Chan’s extradition under these circumstances without clear proof that the statute of limitations has not expired would violate his constitutionally guaranteed rights,” the RTC said.
The US government sought for reconsideration of the ruling but the RTC rejected it on September 12, 2022.
The case was then elevated to the CA, which ruled in favor of Chan.
“In the instant case, the records evince that although the petition for the extradition of Chan filed before the RTC encompasses a discourse on the statute of limitations applicable to the prosecution of the offenses charged, it conspicuously fails to address whether the prosecution or the execution of the penalty is tolled during the pendency of the extradition proceedings,” the CA held.
It added that the provision of such a critical information is “indispensable, as it enables the requested 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.”
The CA pointed out the offenses for which Chan was charged were consummated in December 1999 while another reached completion in March 1998, while the extradition petition was filed only in 2006.
“Crucially, the petition also noticeably omits any discussion or proof of time limitations applicable to the enforcement of the sentence imposed upon the person sought to be extradited. As previously underscored, pursuant to the RP-US Extradition Treaty, a request for extradition must be accompanied by a statement outlining the legal provisions that prescribed time constraints on both the prosecution and the execution of penalties concerning the offenses charged,” the CA explained.
As to Chan’s conviction in one of the cases, the CA also stated the same point, adding that the extradition petition should have been accompanied by a specific averment concerning the prescriptive period for the enforcement of penalties, if any.
“Such an allegation is essential to ascertain whether the penalty imposed has not yet prescribed, given that nearly six years had elapsed between the rendition of judgment and the filing of the petition on 10 January 2006,” it added.
While it agreed with the RTC ruling, the CA disagreed with its conclusion that the cases and evidence against Chan were “politically motivated.”
“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,” it said.
Concurring with the ruling are Associate Justices Nina Antonio- Valenzuela and Florencio Mamauag Jr.
