Title
Aquino vs. Heirs of Calayag
Case
G.R. No. 158461
Decision Date
Aug 22, 2012
A patient died after a caesarean section due to anesthesia and surgical negligence; doctors held liable, hospital owner absolved.
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Case Digest (G.R. No. 158461)

Facts:

Patient's Condition and Initial Treatment
On November 13, 1990, Raymunda Calayag, experiencing labor pains and bleeding, was brought by her husband, Rodrigo Calayag, to St. Michael's Clinic in Malolos, Bulacan, owned by Dr. Divinia Unite. Dr. Unite diagnosed the need for a caesarean section, which she recommended be performed at the better-equipped Sacred Heart Hospital (SHH), owned by Dr. Alberto Reyes.

Operation and Complications
Raymunda was admitted to SHH at 2:16 PM that same day. Dr. Eduardo Aquino, the anesthesiologist, administered anesthesia at 2:48 PM. At 2:53 PM, Dr. Unite delivered a stillborn baby. Shortly after, Raymunda turned cyanotic, her vital signs disappeared, and she experienced a cardio-respiratory arrest. The team revived her after 5–7 minutes, but she remained unconscious.

Post-Operation Care and Death
Raymunda was referred to Dr. Farinas, an internist, who confirmed she had suffered a cardiac arrest during the operation. She was later transferred to Medical Center Manila (MCM), where she was diagnosed as being in a vegetative state due to anoxic brain injury. Despite further treatment, Raymunda’s condition did not improve, and she died on December 14, 1990.

Legal Proceedings
Rodrigo Calayag and his children filed a complaint for damages against Dr. Unite, Dr. Aquino, and Dr. Reyes, alleging negligence in the operation. The Regional Trial Court (RTC) found the doctors liable, a decision affirmed by the Court of Appeals.

Issue:

  1. Whether Dr. Unite (surgeon) and Dr. Aquino (anesthesiologist) were negligent in handling Raymunda’s operation, resulting in her death.
  2. Whether Dr. Reyes, as the hospital owner, is liable for the negligence of Dr. Unite and Dr. Aquino.

Ruling:

The Supreme Court denied the petitions filed by the doctors, affirming the decision of the Court of Appeals with modifications. Dr. Unite and Dr. Aquino were held liable for negligence, while Dr. Reyes was absolved of liability.

Ratio:

  1. Negligence of Dr. Unite and Dr. Aquino

    • Dr. Aquino was found negligent for administering high spinal anesthesia instead of low or mid-spinal anesthesia, which led to Raymunda’s cardio-respiratory arrest.
    • Dr. Unite failed to monitor Raymunda’s condition adequately, particularly during the critical period following the arrest, which could have prevented brain damage.
    • The absence of critical notations in the operation record, such as the timing of the arrest, further demonstrated negligence.
  2. Liability of Dr. Reyes

    • Dr. Reyes was not liable as Dr. Unite and Dr. Aquino were not his employees, and there was no evidence of supervisory control or negligence in hospital facilities or staff.
    • The doctrine of ostensible agency did not apply, as there was no evidence to suggest that Raymunda and her husband believed the doctors were hospital employees.
  3. Award of Damages

    • The heirs of Raymunda were awarded P50,000.00 as death indemnity, in addition to other damages affirmed by the Court of Appeals.


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