G.R. No. 159132 - Cayao-Lasam vs. Spouses Ramolete

On July 28, 1994, Editha Ramolete, three months pregnant, was admitted to Lorma Medical Center (LMC) due to profuse vaginal bleeding upon advice of Dr. Fe Cayao-Lasam (petitioner).
A pelvic sonogram revealed weak fetal cardiac pulsation and absence of fetal movement; petitioner advised Dilatation and Curettage (D&C) after continued bleeding.
On July 30, 1994, petitioner performed the D&C; Editha was discharged on July 31, 1994, with instructions to return for follow-up on August 5, 1994.

On September 16, 1994, Editha was readmitted with vomiting, severe abdominal pain; laparotomy revealed massive intra-abdominal hemorrhage and ruptured uterus, necessitating hysterectomy and resulting sterility.
On November 7, 1994, Editha and her husband, Claro Ramolete, filed a complaint for gross negligence and malpractice against petitioner before the Professional Regulation Commission (PRC), alleging failure to monitor, examine internally, remove the fetus, and to provide due care.
Petitioner’s Answer denied negligence, detailing telephone orders, rounds visit, internal examinations on July 29 and 30, 1994, inability to locate abortus during D&C, patient’s insistence on discharge, and patient’s failure to return for follow-up.

On March 4, 1999, the PRC Board of Medicine exonerated petitioner, finding an interstitial ectopic pregnancy protected by uterine muscle, non-removable by curettage, and that petitioner could not be faulted for misdiagnosis.
On November 22, 2000, the PRC en banc reversed, revoked petitioner’s license, holding she acted with gross negligence.
Petitioner sought review before the Court of Appeals (CA); on July 4, 2003, the CA dismissed her petition for lack of proper remedy, ruling PRC was not among quasi-judicial agencies under Rule 43 and that appeal to the President was the exclusive remedy under R.A. No. 2382.
Petitioner filed a Rule 45 petition with the Supreme Court contesting CA’s procedural rulings, PRC’s denial of due process, absence of expert testimony, and factual findings contrary to evidence.

Whether PRC decisions are appealable to the CA under Rule 43 of the Rules of Court despite not being expressly enumerated.
Whether the CA correctly held that appeal from PRC decisions lies exclusively to the Office of the President under R.A. No. 2382.

Whether PRC’s revocation of petitioner’s license violated her right to due process by not serving her with respondents’ Memorandum on Appeal.
Whether PRC’s factual findings and conclusions on medical negligence and proximate cause lacked support in evidence and expert testimony.