G.R. No. 189218 - Our Lady of Lourdes Hospital vs. Spouses Capanzana

Regina Capanzana, 40-year-old nurse and clinical instructor, pregnant with third child, scheduled for elective C-section on January 2, 1998.
On December 26, 1997, she went into active labor and underwent emergency C-section at Our Lady of Lourdes Hospital. Pre-operative exam by Dr. Miriam Ramos (ob-gyne) and Dr. Milagros Joyce Santos (anesthesiologist) revealed no signs of tuberculosis, rheumatic fever, or cardiac disease. She delivered a healthy baby boy and was transferred to a regular room once stable.

At 2:30 a.m. on December 27, 1997, while under her niece’s watch, Regina complained of headache, chills, restlessness, dyspnea, then became cyanotic. Chest X-ray showed pulmonary edema; impression: possible amniotic fluid embolism. She was moved to ICU and placed on a ventilator.
On January 2, 1998, transferred to Cardinal Santos Hospital; diagnosed with rheumatic mitral stenosis and mild pulmonary hypertension, leading to cardiopulmonary arrest and hypoxic brain injury. She emerged in a vegetative state, losing speech, sight, hearing, and limb function; discharged January 19, 1998.

Spouses Capanzana sued the hospital, Dr. Ramos, Dr. Santos, and unnamed nurses for negligence: failure to detect heart disease, refer for cardiac clearance, manage fluids, and promptly provide oxygen (actual damages ₱814,645.80; compensatory ₱3,416,278.40; moral ₱5,000,000; exemplary ₱2,000,000; attorney’s fees ₱500,000).
Answers: hospital and doctors denied negligence, citing emergency circumstances and lack of clinical signs; nurses unserved except Florita Ballano (midwife), who denied breach.
Trial: plaintiffs presented cardiologists, neurologist, physician, relatives; defense presented the attending doctors and hospital administrators. Patient died May 11, 2005; heirs substituted.

Doctors Ramos and Santos found not negligent; amniotic fluid embolism unforeseeable cause of pulmonary edema and arrest.
Nurses found negligent: 10- to 15-minute delay in responding to Regina’s calls and in administering oxygen contributed to hypoxic encephalopathy.
Hospital exonerated under corporate negligence: it exercised “diligence of a good father of a family” in hiring and supervising nurses.
Only Ballano held liable; ordered to pay actual damages ₱299,102.04, moral ₱100,000, compensatory ₱1,950,269.80, attorney’s fees ₱100,000, plus costs. Claims against hospital and doctors dismissed.

Affirmed that proximate cause was hypoxic encephalopathy due to delayed oxygen.
Exonerated Drs. Ramos and Santos based on lack of clinical signs and accepted expert testimony.
Exonerated Ballano: as midwife, unclear if on duty or responsible for nurse duties.
Held hospital directly liable under corporate responsibility: proved due diligence in selection but not in supervision; gross negligence in oxygen tank accessibility on a 27-bed ward.
Awarded same sums as RTC but against the hospital. Motion for reconsideration denied.

Petition partly meritorious; factual findings of negligence by nurses and liability of hospital affirmed.
Doctors’ exoneration affirmed; hospital’s vicarious liability under Art. 2180 (in relation to Art. 2176) confirmed due to failure to prove diligent supervision.
Modified award: actual damages reduced by unpaid hospital bill of ₱20,141.60; interest of 6% per annum on the resulting amount; compensatory damages ₱1,950,269.80; moral damages ₱100,000; attorney’s fees ₱100,000; costs of suit.

Whether the nurses breached their duty by delaying oxygen administration and proper referral, causing Regina’s hypoxic brain injury.
Whether the hospital is directly liable under Article 2180 for its nurses’ negligence, having proven diligence in selection but failing in supervision.
Whether Drs. Ramos and Santos were negligent in pre-operative detection and management of Regina’s cardiac condition.
Whether the hospital’s counterclaims and the request to take additional deposition warranted remand.