G.R. No. 227775 . October 10, 2022
ELEANOR REYNO AND ELSA DE VERA, PETITIONERS, VS. GEORGE BALTAZAR AND JOEL BALTAZAR, RESPONDENTS.

FACTS

Teresita Laurena Baltazar, a diabetic patient, was admitted to Echague District Hospital (EDH) for a debridement procedure on her foot. Her attending physician, Dr. Malvar, in consultation with a specialist, Dr. De Guzman, prescribed a regimen of insulin injections to be administered by the nurses at specific times, each preceded by a Random Blood Sugar (RBS) test. On the day of the procedure, nurse Elsa De Vera administered insulin at 11:30 a.m. The surgery concluded successfully at 12:20 p.m. Later, during nurse Eleanor Reyno’s shift, she administered insulin at 5:20 p.m. Subsequently, Reyno removed Teresita’s oxygen mask, allegedly due to a shortage and with claimed clearance from the anesthesiologist. Shortly after, Teresita experienced respiratory distress. Despite reattaching the oxygen and calling for emergency assistance from the resident physician, Dr. Caramancion, Teresita was pronounced dead at 7:00 p.m. Her heirs, George and Joel Baltazar, filed a damages suit against the hospital personnel, including nurses Reyno and De Vera.
The Regional Trial Court dismissed the complaint, finding no negligence. It held the cause of death was unproven without an autopsy and that the nurses acted with due care. The Court of Appeals reversed this decision concerning nurses Reyno and De Vera. It found De Vera negligent for administering insulin without first conducting the required RBS test. It found Reyno negligent for the premature removal of the oxygen mask without proper authorization and for her failure to exercise due diligence in monitoring the patient afterward. The CA held them jointly and severally liable for damages. The nurses elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in finding petitioners Eleanor Reyno and Elsa De Vera negligent and thus solidarily liable for damages arising from the death of Teresita Baltazar.

RULING

The Supreme Court denied the petition and affirmed the CA’s decision. On the issue of negligence, the Court applied the four elements of a quasi-delict: (1) damages suffered by the plaintiff; (2) fault or negligence of the defendant; (3) causation between the fault and the damages; and (4) no pre-existing contractual relation. The death of Teresita and the resulting moral damages were established. The core inquiry was whether the nurses breached their duty of care.
For nurse De Vera, the specialist’s instruction was clear: an RBS test must precede every insulin injection. Her admission that she administered insulin at 11:30 a.m. without a recorded RBS test constituted a breach of this specific protocol. This failure to follow a direct medical order designed to ensure patient safety established negligence per se. For nurse Reyno, her act of removing the oxygen mask was critical. The Court found her claim of securing prior clearance from Dr. Cabansag unsupported by evidence, as no written order existed in the chart and the doctor was not presented to corroborate. Her subsequent defensive reaction to the family’s concern and the lack of diligent monitoring after the removal, failing to immediately recognize the patient’s deteriorating condition, further demonstrated a departure from the standard of care expected of a nurse.
On causation, the Court clarified that direct proof is not always required; proximate cause can be inferred from the sequence of events. The confluence of De Vera’s unmonitored insulin administration and Reyno’s removal of respiratory support, followed closely by the patient’s rapid decline and death, established a reasonable