GR 158461; (August, 2012) (Digest)

G.R. No. 158461, 158634, 158818, August 22, 2012
DR. EDUARDO AQUINO, DR. ALBERTO C. REYES, and DR. DIVINIA UNITE, PETITIONERS, VS. HEIRS OF RAYMUNDA CALAYAG, RESPONDENTS.

FACTS

On November 13, 1990, Raymunda Calayag, experiencing labor pains and bleeding, was brought to St. Michael’s Clinic of Dr. Divinia Unite. Dr. Unite determined a caesarean section was necessary and referred her to the better-equipped Sacred Heart Hospital (SHH), owned by Dr. Alberto Reyes. At SHH, Dr. Eduardo Aquino administered spinal anesthesia. Dr. Unite then delivered a stillborn baby. Minutes later, Raymunda became cyanotic, suffered cardio-respiratory arrest, and was resuscitated after 5-7 minutes. She never regained consciousness, entering a vegetative state.
Raymunda was transferred to another hospital where her surgical wound later split open, requiring re-suturing. She was discharged and died on December 14, 1990. Her heirs filed a damages suit against Dr. Unite (surgeon), Dr. Aquino (anesthesiologist), and Dr. Reyes (hospital owner) for negligence. The Regional Trial Court found all three liable, a decision affirmed by the Court of Appeals. The doctors filed separate petitions for review.

ISSUE

1. Whether Dr. Unite and Dr. Aquino were negligent in handling Raymunda’s operation.
2. Whether Dr. Reyes, as hospital owner, is liable for the negligence of the attending physicians.

RULING

The Supreme Court DENIED the petitions, affirming the lower courts’ findings of liability for medical malpractice. On the first issue, the Court found both Dr. Aquino and Dr. Unite negligent. For medical malpractice, a plaintiff must establish: the physician’s duty of care, a breach of that duty, an injury, and a proximate causal connection between breach and injury. Expert testimony is crucial. The Court credited the testimony of the heirs’ expert witness, Dr. Libarnes, a neurologist who treated Raymunda post-operation. He opined that the proximate cause of her anoxic brain injury and vegetative state was the cardio-respiratory arrest during surgery, which was likely due to an anesthetic accident from high spinal anesthesia—a matter within Dr. Aquino’s responsibility. The Court rejected the petitioners’ defense that other factors could have caused the arrest, as they failed to present convincing expert testimony to rebut Dr. Libarnes.
Dr. Unite was also found negligent. Her post-operative care was deficient, as evidenced by the splitting open of Raymunda’s surgical wound shortly after Dr. Unite removed the stitches. Furthermore, her failure to maintain complete and accurate medical records, particularly the anesthesia record, violated standard medical practice and constituted negligence. On the second issue, the Court held Dr. Reyes, as hospital owner, solidarily liable under the doctrine of respondeat superior. The hospital, by accrediting Dr. Unite and providing its facilities, held itself out as offering medical services. The public reasonably expects the hospital to ensure the competence of medical practitioners it allows to use its premises. Therefore, the hospital is vicariously liable for the negligence of physicians practicing within its walls. All petitioners were ordered to pay damages solidarily.