G.R. No. 86890 January 21, 1994
LEANDRO CARILLO, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Dr. Leandro Carillo, an anesthetist, was convicted by the Regional Trial Court of simple negligence resulting in homicide for the death of his 13-year-old patient, Catherine Acosta. The conviction was affirmed by the Court of Appeals. The information alleged that on or about May 31, 1981, in Parañaque, Metro Manila, petitioner and his co-accused, surgeon Dr. Emilio Madrid, conspired and operated on Catherine Acosta in a reckless, careless, and imprudent manner, neglecting to exercise their medical know-how and departing from recognized standards, which negligence caused her death. The prosecution presented witnesses, including Catherine’s parents and expert witnesses Dr. Horacio Buendia and Dr. Nieto Salvador. The defense did not present evidence after its motion for extension to file a demurrer was denied. The Court of Appeals found that Catherine suffered from an overdose of or adverse reaction to anesthesia, particularly the administration of Nubain without prior weighing of the patient, which triggered a heart attack as a post-operative complication, leading to brain hemorrhage and death. The appellate court found criminal negligence in petitioner’s failure to observe the required standard of diligence, including administering Nubain without weighing the patient and leaving the hospital immediately after reviving Catherine’s heartbeat, depriving her of immediate medical assistance when she suffered a heart attack shortly after.

ISSUE

Whether the Court of Appeals erred in affirming petitioner’s conviction for simple negligence resulting in homicide based on the factual conclusions drawn from the evidence.

RULING

The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the findings of fact of the Court of Appeals are conclusive and binding, absent any showing of grave abuse of discretion or misapprehension of facts. The Court found that the evidence established petitioner’s negligence beyond reasonable doubt. Petitioner administered Nubain without first weighing the patient to determine the safe dosage, which was a departure from standard medical practice. Furthermore, petitioner and Dr. Madrid left the hospital immediately after reviving Catherine’s heartbeat, failing to monitor her condition and provide immediate expert assistance when she suffered a heart attack shortly after. This constituted reckless imprudence, defined as the failure to observe the necessary precaution to avoid injury to persons. The Court also upheld the solidary civil liability of the accused for damages awarded to the heirs of Catherine Acosta.