Facts:
On April 22, 1988,
Edmer Cortejo, an eleven-year-old boy, was brought to the Emergency Room of
San Juan de Dios Hospital (SJDH) in Makati City by his mother, Jesusa Cortejo, complaining of fever, chest and stomach pain, and difficulty in breathing. Initial assessment by Dr. Ramoncito Livelo and a chest X-ray led to a working diagnosis of bronchopneumonia. Mrs. Cortejo’s Fortune Care referral assigned pediatrician
Dr. Noel Casumpang, who confirmed bronchopneumonia on two successive visits despite parental reports of persistent high fever, throat irritation, and traces of blood in Edmer’s sputum. On April 23, resident physician
Dr. Ruby Sanga-Miranda tended to Edmer after he vomited phlegm streaked with blood; she noted respiratory distress, low-grade fever, and non-typical skin rashes but deferred to the initial bronchopneumonia diagnosis. After further bleeding episodes that afternoon, Dr. Miranda conducted a tourniquet test and informed Dr. Casumpang, who finally ordered hemato
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