GR 172406; (October, 2007) (Digest)
G.R. No. 172406 ; October 11, 2007
CONCEPCION ILAO-ORETA, Petitioner, vs. SPOUSES EVA MARIE and BENEDICTO NOEL RONQUILLO, Respondents.
FACTS
Respondents, spouses Ronquillo, consulted petitioner Dr. Concepcion Ilao-Oreta, an infertility specialist, regarding their inability to conceive. Upon Dr. Ilao-Oreta’s advice, Eva Marie Ronquillo agreed to undergo a laparoscopic procedure scheduled for April 5, 1999, at 2:00 p.m. at St. Luke’s Medical Center. The spouses complied with all pre-operative requirements, checking into the hospital early that morning. However, Dr. Ilao-Oreta failed to arrive for the scheduled surgery. It was later revealed she was on a return flight from her honeymoon in Hawaii, having miscalculated the time difference and arriving in Manila only at 10:00 p.m. that day. No prior notice of cancellation was given to the patients.
The spouses filed a complaint for breach of contract and damages against Dr. Ilao-Oreta and St. Luke’s Medical Center. The Regional Trial Court found the failure was not intentional and awarded only actual damages. On appeal, the Court of Appeals modified the decision, finding Dr. Ilao-Oreta grossly negligent and holding her jointly and severally liable with the hospital for increased actual damages, and additionally liable for moral damages, exemplary damages, and attorney’s fees.
ISSUE
Whether the Court of Appeals erred in finding Dr. Ilao-Oreta grossly negligent and in awarding moral damages, exemplary damages, attorney’s fees, and increased actual damages.
RULING
The Supreme Court granted the petition, modifying the appellate court’s decision. The Court held that Dr. Ilao-Oreta was not grossly negligent. Gross negligence implies a want of even slight care or a conscious indifference to consequences. The records showed the doctor, in good faith, made preparations before her trip, including leaving an admitting order and instructing hospital staff. Her failure to account for the time difference was an honest mistake, not a willful or wanton disregard. Upon realizing her error, she immediately attempted to contact the patients to apologize and reschedule. This conduct negated a finding of gross negligence, which is a prerequisite for awards of moral and exemplary damages in breach of contract cases absent fraud or bad faith.
Consequently, the awards for moral and exemplary damages and attorney’s fees were deleted. Regarding actual damages, the Court reduced the award to only the proven out-of-pocket expenses directly caused by the breach (hospital charges for the pre-operative procedures), amounting to ₱2,288.70, with legal interest. The claim for Noel Ronquillo’s loss of income was unsupported by adequate evidence. The hospital’s liability was also eliminated as it performed its pre-operative duties without fault, and the breach was solely attributable to the doctor’s personal miscalculation.