G.R. No. 175540 - Alano vs. Magud-Logmao

Petitioner is Dr. Filoteo A. Alano, Executive Director of the National Kidney Institute (NKI).
Respondent is Zenaida Magud-Logmao, mother of the deceased Arnelito Logmao.
On March 1, 1988, Arnelito (18 years old) was brought to East Avenue Medical Center (EAMC) after allegedly falling from an overpass; hospital records misidentified him as “Angelito Lugmoso.”

At EAMC, he was drowsy with alcoholic breath; skull X-ray negative for fracture; developed generalized seizures by 4:00 a.m. on March 2, 1988.
Required ICU admission and mechanical ventilation; no available beds or ventilators, prompting transfer to NKI at 10:10 a.m. on March 2.

At NKI, still identified as Angelito Lugmoso; no relatives present. Transplant Coordinator Jennifer Misa enlisted media and police assistance to locate next of kin.
On March 3, 1988, doctors declared him brain dead after EEG confirmation. Dr. Enrique T. Ona identified him as a potential organ donor.
Dr. Ona sought authorization from Dr. Alano and approval from the NBI Medico-Legal Section under R.A. 349 (as amended by P.D. 856).

Dr. Alano issued a memorandum authorizing retrieval of kidneys, pancreas, liver, and heart “only if all reasonable efforts” to locate relatives were exerted and NBI notified.
NBI Medico-Legal Officer verbally agreed to organ retrieval despite absence of family consent.
On March 3, 1988, the medical team removed the organs; kidneys and pancreas transplanted to two recipients; procedure completed by 11:00 p.m.

Cadaver embalmed for 15 days to continue next-of-kin search; press release of successful double transplant issued March 11, 1988.
Respondent learned via television of a donor with similar name; family identified the body at La Funeraria Oro.
On April 29, 1988, respondent filed a complaint for damages against multiple defendants, alleging conspiracy to harvest organs while son was alive and conceal his identity.
RTC (Jan. 17, 2000) found only Dr. Alano liable for quasi-delict; awarded P188,740.90 actual, P500,000 moral, P500,000 exemplary damages, and P300,000 attorney’s fees.
CA (Mar. 31, 2006) affirmed with modification: deleted actual damages, reduced moral to P250,000, exemplary to P200,000, and attorney’s fees to P100,000.

Whether the Court of Appeals disregarded existing jurisprudence by finding Dr. Alano liable for moral and exemplary damages and attorney’s fees absent a finding that his act was the proximate cause of respondent’s injury.

Whether Dr. Alano acted in good faith and pursuant to law (R.A. 349 as amended by P.D. 856) when he authorized the removal of organs, thus negating negligence.

Whether the awards of moral and exemplary damages and attorney’s fees were contrary to established jurisprudence.