Case Digest (G.R. No. 177407) Core Legal Reasoning Model
Facts:
In Rico Rommel Atienza v. Board of Medicine and Editha Sioson (G.R. No. 177407, February 9, 2011), petitioner Rico Rommel Atienza was one of four doctors accused by Editha Sioson (through her husband, Romeo Sioson, as complainant) of gross negligence and/or incompetence before the Board of Medicine (“BOM”) in Administrative Case No. 1882. Editha first consulted Rizal Medical Center (RMC) on February 4, 1995 for lumbar pain and, in 1999, was referred to Dr. Pedro Lantin III, who ordered diagnostic tests revealing a normal right kidney but a non-functioning left kidney. Despite that finding, Editha underwent a kidney operation in September 1999 during which her fully functional right kidney was removed. On February 18, 2000, the Siosons filed their complaint before the BOM against Drs. Judd dela Vega, Pedro Lantin III, Gerardo Antonio Florendo, and Atienza. During the administrative hearing, Editha formally offered four exhibits—certified photocopies of X-ray request forms dated
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Case Digest (G.R. No. 177407) Expanded Legal Reasoning Model
Facts:
- Medical Background and Treatment
- In February 1995 and again in 1999, private respondent Editha Sioson experienced lumbar pains and underwent diagnostic tests at Rizal Medical Center (RMC).
- Tests revealed a non-functioning left kidney; she underwent a kidney operation in September 1999.
- Filing of Administrative Complaint
- On February 18, 2000, Romeo and Editha Sioson filed before the Board of Medicine (BOM) a complaint for gross negligence and/or incompetence against Drs. Judd dela Vega, Pedro Lantin III, Gerardo Antonio Florendo, and petitioner Rico Rommel Atienza.
- The complaint alleged the removal of Editha’s healthy right kidney instead of her non-functioning left kidney.
- Documentary Evidence and Procedural History
- Editha offered Exhibits A–D (certified photocopies of X-ray/ultrasound request forms dated between 1996 and 1999) to prove the anatomical positions of her kidneys.
- Petitioner objected on grounds of hearsay, lack of authentication, and best evidence rule violation. The BOM admitted the exhibits (May 26, 2004 Order) and denied reconsideration (October 8, 2004 Order).
- Petitioner filed a Rule 65 petition for certiorari with the Court of Appeals (CA), which dismissed it on September 22, 2006. He then elevated the case to the Supreme Court.
Issues:
- Procedural Issue
- Whether certiorari under Rule 65 is the proper remedy to assail the BOM’s interlocutory orders admitting documentary evidence.
- Substantive Issue
- Whether the CA gravely erred in upholding the admission of allegedly incompetent and inadmissible evidence, potentially depriving petitioner of his professional license.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)