G.R. No. 250919 . November 10, 2021
JUDE CARLO M. ALLAREY, ET AL., PETITIONERS, VS. DR. MA. DITAS F. DELA CRUZ AND MANILA EAST MEDICAL CENTER, RESPONDENTS.

FACTS

Petitioners, the common-law partner, children, and parents of the late Marissa Baco, filed a complaint for damages based on quasi-delict against Dr. Ma. Ditas F. Dela Cruz and Manila East Medical Center, Inc. (MEMCI). Marissa, who had a previous cesarean section, died on August 29, 2006, after giving birth prematurely to Julia Carla, who also died the next day. On August 28, 2006, Marissa experienced bleeding and was brought to Dr. Dela Cruz’s clinic, who then endorsed her to MEMCI. She was admitted and monitored. The next day, after plans for discharge, Marissa experienced profuse bleeding again. An emergency cesarean section was performed, and Julia Carla was delivered. Due to massive bleeding and a deeply adherent placenta, an emergency hysterectomy was performed. Despite procedures and blood transfusions, Marissa died. Dr. Dela Cruz denied negligence, attributing the death to “Cardio Respiratory Arrest secondary to Hypovolemic shock; Placenta Accreta; T/C Amniotic Fluid Embolism.” MEMCI denied liability, asserting no employer-employee relationship with Dr. Dela Cruz and that it exercised due diligence in selecting its consultants. The Regional Trial Court dismissed the complaint, finding petitioners failed to prove by preponderance of evidence that Dr. Dela Cruz failed to observe the standard of care. The Court of Appeals affirmed the dismissal.

ISSUE

Whether the Court of Appeals erred in affirming the dismissal of the complaint for damages based on quasi-delict against respondents, thereby finding no negligence on the part of Dr. Dela Cruz and no liability on the part of MEMCI.

RULING

The Supreme Court DENIED the petition and AFFIRMED the Decision of the Court of Appeals. The Court held that petitioners failed to prove by preponderance of evidence that Dr. Dela Cruz was negligent in her care of Marissa. In medical negligence cases, the claimant must prove: (1) the duty owed by the physician to the patient according to the standard of care; (2) a breach of that duty; (3) injury; and (4) a proximate causal connection between the breach and the injury. Expert testimony is generally required to establish the standard of care and a deviation therefrom, given the technical nature of medical practice. Petitioners did not present any expert witness to testify that Dr. Dela Cruz failed to meet the standard of care. The Court found that Dr. Dela Cruz’s actions—including the pre-natal care, admission, monitoring, administration of tocolysis, and performance of emergency cesarean section and hysterectomy upon detecting profuse bleeding and placenta accreta—were in accordance with standard medical practice. A negative outcome does not automatically imply negligence. Furthermore, MEMCI was not liable as petitioners failed to prove that the hospital was negligent in the selection and supervision of Dr. Dela Cruz or that it had an employer-employee relationship with her. The hospital’s consultants, like Dr. Dela Cruz, are independent contractors, and the hospital provided the necessary facilities and staff in accordance with her instructions.