Case Digest (G.R. No. 118231) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Dr. Victoria L. Batiquin and Allan Batiquin v. Court of Appeals; Quedo D. Acogido and Flotilde G. Villegas (327 Phil. 965, April 28, 1997), Dr. Victoria L. Batiquin served as a Resident Physician (and, from 1987 to September 1989, Acting Head of the Department of Obstetrics and Gynecology) at the Negros Oriental Provincial Hospital in Dumaguete City. On September 21, 1988, she performed a cesarean section on Mrs. Flotilde G. Villegas, delivering a healthy child. Mrs. Villegas remained confined until September 27, 1988, after which she began experiencing recurring abdominal pain, fever, and loss of appetite. Despite follow-up consultations with Dr. Batiquin and prescribed medication, her condition worsened. On January 20, 1989, Dr. Ma. Salud Kho found Mrs. Villegas to be infected, discovered ovarian cysts discharging pus, and—upon opening the abdomen—a piece of rubber embedded near the right ovary. Dr. Kho performed a second surgery, removing the foreign body and saving Mrs. V Case Digest (G.R. No. 118231) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- Dr. Victoria L. Batiquin (petitioner) served as Resident Physician (Jan. 9, 1978–Sept. 1989) and Acting Head of Obstetrics & Gynecology at Negros Oriental Provincial Hospital, Dumaguete City.
- Spouses Quedo D. Acogido and Flotilde G. Villegas (respondents); Mrs. Villegas was a private prenatal patient of Dr. Batiquin.
- Cesarean Section and Post-Operative Course
- On September 21, 1988, Dr. Batiquin, assisted by Dr. Doris Teresita Sy, C.I. and O.R. Nurse Arlene Diones, and student nurses, performed a simple cesarean section; mother and baby were initially well.
- Mrs. Villegas discharged on September 28, 1988; paid P1,500 “professional fee”; soon developed abdominal pain, fever, anorexia; took prescribed medications through December 1988; returned to work early November.
- Second Consultation and Discovery of Foreign Body
- On January 20, 1989, Mrs. Villegas consulted Dr. Ma. Salud Kho at Holy Child’s Hospital; examined as feverish, pale, tachypneic, with abdominal mass.
- Dr. Kho performed laparotomy, found pus in both ovarian cysts, dirty purulence behind uterus, and a 2″×¾″ piece of rubber (resembling torn glove or drain) embedded beside the uterus; attributed patient’s infection and suffering to retained rubber.
- Documentary Evidence and Trial Court Findings
- Respondents offered Medical Certificate, Progress Record, Anesthesia Record, Nurse’s Record, and Discharge Summary noting rubber; trial court excluded these as hearsay, except the Medical Certificate.
- Trial court also questioned Dr. Kho’s first-hand knowledge and credited Dr. Batiquin’s and Dr. Sy’s negative testimony that no rubber drain or glove tear occurred; dismissed respondents’ damage claim.
- Court of Appeals Decision
- On May 11, 1994, the Court of Appeals (CA-G.R. CV No. 30851) reversed the trial court, crediting Dr. Kho’s positive testimony of retained rubber causing infection.
- Awarded respondents P17,000 actual damages; P100,000 moral damages; P20,000 exemplary damages; P25,000 attorney’s fees; costs of litigation.
Issues:
- Did the Court of Appeals commit grave abuse of discretion by making factual findings not supported by the record?
- Did the Court of Appeals exceed its jurisdiction in crediting testimonies alleged to be contradictory or false?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)