by: Mickey Ingles

I had the honor of sitting as a panelist at the Philippine Heart Association-Philippine College of Cardiology 56^th Annual Convention and Scientific Meeting last May 27, 2026. The panel—a who’s who of Filipino cardiologists and geneticists—discussed the genetic, medical, ethical, legal, and societal implications of precision cardiac care for young athletes. 

As I am obviously not a cardiologist or geneticist, I learned a lot about the troubling instances of sudden cardiac death in young athletes in the Philippines, inherited cardiomyopathies, advances in genetics and medicine, and how precision cardiomyopathy care can prevent the untimely deaths of young athletes. My contributions revolved around possible liabilities of organizers in cases of deaths during sports events, medical malpractice issues, and the legal implications of pre-competition screenings. 

The discussions also touched on the importance of having automated external defibrillators (AEDs) readily available in the unfortunate event that an athlete suffers sudden cardiac arrest during a sports competition. AEDs are portable devices that can treat sudden cardiac arrest. 

To be specific, the panel raised the issue on the lack of AEDs in sports training facilities and venues. 

One panelist even stated that an AED would have likely saved the lives of certain young athletes who sadly passed away last year because of sudden cardiac arrest during training. It brought to mind Danish captain Christian Eriksen and how he suffered sudden cardiac arrest during a football game in 2021. Medical staff immediately rushed into the field, administered CPR, and used an AED. Eriksen survived the ordeal, went on to play for Manchester United, and still plays today for VfL Wolfsburg. 

As there is still much to be done in terms of ensuring athletes are fit to play pre-training or pre-competition, the question on readily available AEDs is an important one.  If it remains operationally difficult to properly screen for conditions beforehand, the best option is to provide the necessary equipment to save lives when sudden cardiac death happens. That equipment is the AED.

This begs the question: as AEDs have been proven as life-saving, are there any laws that actually mandate them?

Unfortunately, there are none. 

There is no law mandating AEDs in public places, much less sports centers or venues. Some cities have passed ordinances requiring the installation of AEDs, but given the importance of AEDs, it is quite puzzling that there is no overarching national law that requires AEDs. Senator Lito Lapid filed a bill in 2022 requiring AEDs in public spaces, but this never became a law.

The closest law we have is R.A. 10871, which mandates all basic education schools to provide students with basic life support training, such as CPR. R.A. 10871 is also known as the Samboy Lim Act, named after the skywalking legend who had collapsed during a basketball game in 2014. The main proponent of the law was none other than Coach Yeng Guiao, who was serving as district representative at that time. 

While there is no national legislation on the matter, I believe that mandatory AEDs are still part of the duty of diligence of organizers, venue owners, and sports teams. They should provide it. And organizing a sports event or conducting practices without AEDs can expose them to liability.

In Abrogar v. Cosmos Bottling, the Court held a race organizer of a junior marathon liable for the tragic death of a young runner who was struck by a jeepney during the course of the race. In stating that the race organizer was negligent, the court applied the baseline duty to exercise proper diligence. 

As a basic tenet of torts law, proper diligence is always reckoned on the reasonable foreseeability of risk. Applying this to sports events, sports organizers must adopt adequate safeguards demanded by the persons, time, and place of said event or competition. If kids and minors are involved, then the required diligence is heightened as demanded by the age of the participants. In Abrogar, the organizer breached its duty to exercise proper diligence by failing to adopt proper safeguards in conducting the race—poor route management, poor coordination with the local government, poor supervision of its volunteers—all leading to the untimely death of a child.

With this basic duty to exercise proper diligence in mind, sports organizers, venue owners, and teams must realize that sudden cardiac death of young athletes is a reasonably foreseeable risk. In 2025 alone, four young athletes died because of sudden cardiac death. Four in one year. Given the sensitivity of the matter, some remain unreported. But it cannot be denied that sudden cardiac death is a foreseeable risk that must be guarded against. It has happened before. It can happen again—unless sports organizers, venue owners, and teams equip themselves with AEDs. 

As there is no national law on AEDs, we only have torts-based standards to fall back on. And unfortunately, torts-based standards are typically argued on after-the-fact during litigation. After-the-fact is too late for those who have suffered sudden cardiac death while playing a sport they loved.

Hopefully, Congress can look into the issue and pass a law mandating AEDs. Soon. 

In the meantime, national sports associations, pro leagues, schools, team owners, and athletic associations like the UAAP and NCAA should lead the way to ensure the presence of AEDs in sports venues and training venues. At a minimum, venue owners and facility owners should invest in AEDs (a quick online search pegs AEDs for as low as P38,000.00)—with or without a law mandating it.

In the end, it’s not about legal obligations and liabilities. It’s about saving lives of our athletes.

Mickey Ingles is the editor-in-chief of Batas Sportiva and a partner of ILC Law.