Case Digest (G.R. No. 142625)
Facts:
In Nogales v. Capitol Medical Center, Corazon Nogales, a 37-year-old woman in her fourth pregnancy, was under the exclusive prenatal care of Dr. Oscar Estrada as early as December 1975 when she developed preeclampsia. In the early hours of May 26, 1976, upon experiencing labor pains, Corazon and her husband Rogelio Nogales sought Dr. Estrada, who ordered her immediate admission to Capitol Medical Center (CMC). Rogelio signed the hospital’s admission and consent forms on CMC letterhead, acknowledging Dr. Estrada as the attending physician. During labor, Dr. Estrada directed the administration of valium and syntocinon, and later attempted forceps delivery, resulting in a cervical tear. Corazon suffered profuse postpartum hemorrhage, and despite calls to Dr. Joel Enriquez (anesthesiologist), Dr. Ely Villaflor’s reduced magnesium sulfate dosage, and the eventual order for a hysterectomy by Dr. Noe Espinola, Corazon died at 9:15 a.m. on May 26. In May 1980, the Nogaleses sued CMC, DrCase Digest (G.R. No. 142625)
Facts:
- Prenatal care and admission
- Corazon Nogales, 37, under exclusive care of Dr. Oscar Estrada from December 1975; developed preeclampsia (high blood pressure, leg edema).
- On May 26, 1976, admitted at 2:30 a.m. to Capitol Medical Center (CMC) on Dr. Estrada’s written request; spouse Rogelio Nogales signed “Consent on Admission and Agreement” and “Admission Agreement.”
- Treatment and complications
- Early orders: 10 mg valium IM; IV syntocinon with dextrose in lactated Ringer’s; anesthesiologist Dr. Enriquez observed. Labor progressed; cervix fully dilated at 6:12 a.m.
- Convulsions at 6:13 a.m.; Dr. Estrada ordered 10 g magnesium sulfate, but Dr. Villaflor gave only 2.5 g. Low forceps applied at 6:22 a.m., causing a 1×2.5 cm cervical tear; infant cyanotic, required resuscitation.
- Profuse bleeding at 6:27 a.m.; hypotension; hemacel given as side drip. Blood typing ordered at 7:45 a.m., delivered ~8:00 a.m. Dr. Espinola ordered emergency hysterectomy; patient died at 9:15 a.m. from postpartum hemorrhage.
- Proceedings
- May 14, 1980: Complaint for damages filed against CMC, Dr. Estrada, Drs. Villaflor, Uy, Enriquez, Lacson, Espinola, and Nurse Dumlao. Some respondents defaulted.
- November 22, 1993: RTC Manila found only Dr. Estrada liable; dismissed others. February 6, 1998: CA affirmed; March 21, 2000: CA denied reconsideration. Petition to the Supreme Court followed.
Issues:
- Is CMC vicariously liable for Dr. Estrada’s negligence?
- What is the extent of liability, if any, of Drs. Ely Villaflor, Rosa Uy, Joel Enriquez, Perpetua Lacson, Noe Espinola, and Nurse J. Dumlao?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)