Case Digest (G.R. No. 234851) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In De Jesus v. Uyloan, petitioner Paolo Anthony C. De Jesus filed on November 10, 2015 a complaint for damages under Articles 1170 and 1173 of the New Civil Code against Dr. Romeo F. Uyloan (substituted by his wife, Salvacion Uyloan), Asian Hospital and Medical Center (AHMC), and Dr. John Francois Ojeda. On September 13, 2010, petitioner underwent an abdomino-pelvic sonogram and was diagnosed with cholelithiasis. He agreed to a laparoscopic cholecystectomy at AHMC on September 15, 2010 with Dr. Uyloan as principal surgeon and Dr. Ojeda assisting. Without petitioner’s consent, the procedure was converted into an open cholecystectomy, resulting in substantial blood loss and a transfusion. Discharged on September 19 in “good condition,” he soon suffered vomiting, severe abdominal pain, and bile leakage. A follow-up by Dr. Uyloan attributed these symptoms to the procedure itself, prompting petitioner to seek a second opinion. Subsequent tests revealed the common bile duct—rather tha Case Digest (G.R. No. 234851) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Antecedents and Parties
- On September 13 and 15, 2010, petitioner Paolo Anthony De Jesus underwent an abdomino-pelvic sonogram at Asian Hospital and Medical Center (AHMC). Dr. Romeo F. Uyloan diagnosed cholelithiasis and advised laparoscopic cholecystectomy, with Dr. John Francois Ojeda assisting.
- Petitioner expected a minimally invasive procedure (four small incisions) but was subjected to an open cholecystectomy without his consent, resulting in significant blood loss and transfusion.
- Post-Operative Complications
- Discharged on September 19, 2010 in “good condition,” petitioner experienced persistent abdominal pain, vomiting, and bile leakage into his colostomy bag. Follow-up by Dr. Uyloan attributed symptoms to normal post-operative effects.
- A second opinion and diagnostic tests revealed transection and clipping of the common bile duct instead of the cystic duct, causing bile accumulation around the liver, spleen, kidneys, colon, and limbs. Petitioner underwent corrective surgery on November 19, 2010.
- Procedural History
- On November 10, 2015, petitioner filed a complaint for damages under Articles 1170 and 1173 of the Civil Code against Drs. Uyloan, Ojeda, and AHMC, alleging breach of medical contract and negligence; sought actual, moral, and exemplary damages, attorneys’ fees, litigation costs, and corporate liability of AHMC.
- Respondents moved to dismiss on grounds of prescription (Art. 1146), forum shopping, and lack of jurisdiction. The Regional Trial Court (RTC) of Las Piñas City, Branch 198, denied the motions on May 6, 2016 and August 26, 2016. By June 16, 2017, the Court of Appeals (CA) reversed the RTC and dismissed the complaint as time-barred; reconsideration was denied on October 11, 2017.
Issues:
- Nature of Cause of Action and Applicable Prescription
- Whether petitioner’s medical negligence claim arises from a contract (express or implied) entitling him to a six- or ten-year prescriptive period under Arts. 1144–1145 of the Civil Code.
- Whether the claim is a quasi-delict (tort) subject to a four-year prescriptive period under Art. 1146 of the Civil Code.
- Procedural Question
- Whether the CA gravely abused its discretion in reversing the RTC’s denial of the motions to dismiss based on prescription.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)