Case Digest (G.R. No. 192973) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pedrito Dela Torre v. Dr. Arturo Imbuido, et al. (G.R. No. 192973, September 29, 2014), petitioner Pedrito Dela Torre sued respondents Dr. Arturo Imbuido, Dr. Norma Imbuido as owners and operators of the Divine Spirit General Hospital, and Dr. Nestor Pasamba, for damages arising from the death of Pedrito’s wife, Carmen Castillo Dela Torre. Carmen, due on February 2, 1992, was admitted to the hospital at 11:30 p.m. that day due to failure to deliver. On February 3, a caesarean operation performed by Dr. Nestor delivered a baby boy. Carmen thereafter developed abdominal pain and a urinary tract infection, for which Dr. Norma prescribed medications. When her abdomen distended on February 10, Dr. Norma dismissed it as flatulence but later advised a second operation without specifying its nature. That laparotomy on February 12 did not improve her condition, and Carmen vomited dark red blood before dying on February 13, 1992. The hospital’s death certificate attributed death to car Case Digest (G.R. No. 192973) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Complaint
- Petitioner Pedrito Dela Torre filed a complaint for damages arising from the death of his wife, Carmen Castillo Dela Torre, while confined at Divine Spirit General Hospital in Olongapo City.
- Respondents are Dr. Arturo Imbuido and Dr. Norma Imbuido, owners/operators of Divine Spirit General Hospital, and Dr. Nestor Pasamba, surgeon.
- Medical Events and Treatment
- Admission and First Surgery
- Carmen was due to give birth on February 2, 1992; admitted at 11:30 p.m. that day.
- On February 3 at 3:00 p.m., Carmen underwent a caesarean section performed by Dr. Nestor; healthy baby delivered at 5:30 p.m.
- Post-operative Course and Second Surgery
- February 4: Carmen suffered abdominal pain and urinary retention; diagnosed with UTI and treated by Dr. Norma.
- February 10: Abdominal distension noted; dismissed as flatulence.
- February 12: Second operation (exploratory laparotomy) performed for suspected intestinal obstruction due to adhesions; consent obtained.
- February 13 at 9:30 p.m.: Carmen vomited dark red blood and died later that night.
- Autopsy Findings and Procedural History
- Hospital Certificate of Death: Cardio-respiratory arrest secondary to cerebrovascular accident, hypertension, chronic nephritis induced by pregnancy.
- Dr. Richard Patilano’s Autopsy Report: Cause of death was “shock due to severe peritonitis with multiple intestinal adhesions” post-C-section and laparotomy.
- Trial Court (RTC Branch 75, Olongapo City) Decision (Jan. 28, 2003): Found respondents negligent based on Dr. Patilano’s testimony; awarded Pedrito actual, moral, exemplary damages and attorney’s fees.
- Court of Appeals Decision (Dec. 15, 2009) and Resolution (July 27, 2010): Reversed RTC; ruled no breach of medical standard; granted respondents’ counterclaim of ₱48,515.58 for unpaid hospital charges.
- Supreme Court Petition: Pedrito filed for review on certiorari to reinstate RTC’s award.
Issues:
- Medical Negligence
- Whether respondents breached their duty to exercise the degree of care, skill, and diligence required of medical professionals.
- Whether expert testimony sufficiently established that respondents acted negligently.
- Causation and Evidence
- Whether Dr. Patilano’s autopsy findings and qualifications support a conclusion that respondents’ conduct caused Carmen’s death.
- Whether the evidence meets the requirement of causation within reasonable medical probability rather than speculation.
- Counterclaim
- Whether the respondents’ counterclaim for unpaid hospital bills, professional fees, and medicines in the amount of ₱48,515.58 is valid and enforceable.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)