G.R. No. 160889 . April 27, 2007.
DR. MILAGROS L. CANTRE, Petitioner, vs. SPS. JOHN DAVID Z. GO and NORA S. GO, Respondents.

FACTS

Petitioner Dr. Milagros Cantre, an obstetrician-gynecologist, attended to respondent Nora Go during childbirth. After delivery, Nora suffered postpartum hemorrhage, leading to hypovolemic shock. During emergency procedures to save her life, which included uterine massage and the use of a droplight for warmth, Nora sustained a severe burn on her inner left arm. Respondents discovered the wound post-recovery and sought investigation. Medico-legal findings concluded the injury was a burn consistent with proximity to a droplight, not from a blood pressure cuff as initially suggested by petitioner. Nora underwent skin grafting and scar revision, resulting in permanent disfigurement, pain, and restricted movement.
Respondent spouses filed a complaint for damages. The trial court ruled in their favor, awarding moral, exemplary, and nominal damages, attorney’s fees, and litigation expenses against Dr. Cantre, the hospital, and its director jointly. The Court of Appeals modified the decision, holding only Dr. Cantre liable for moral damages and deleting other awards. Dr. Cantre elevated the case to the Supreme Court via certiorari.

ISSUE

Whether the Court of Appeals committed grave abuse of discretion in affirming petitioner’s liability for damages based on a finding of negligence.

RULING

The Supreme Court denied the petition and affirmed the Court of Appeals. The core legal logic rests on the application of the doctrine of res ipsa loquitur and the standard of care required of medical professionals. A physician-patient relationship existed, establishing a duty of care. The injury—a burn on Nora’s arm—is not a normal incident of childbirth or postpartum emergency procedures. Such an injury does not ordinarily occur in the absence of negligence. Petitioner failed to provide a satisfactory explanation for how the burn occurred despite having exclusive control over the procedure and the instruments used, including the droplight.
The Court found the medico-legal testimony credible, establishing the burn was likely caused by the droplight. Petitioner’s failure to rebut this evidence sufficiently constituted a breach of the duty of care. This breach was the proximate cause of the physical injury and resulting moral suffering. While acknowledging the emergency context and petitioner’s prior good record, the Court held these do not excuse negligence. The award of moral damages was deemed just and equitable compensation for the physical pain, unsightly scarring, and resulting lifestyle limitations suffered by Nora Go. No grave abuse of discretion was found in the appellate court’s factual findings and legal conclusions.