G.R. No. 1468 - People vs Gardner

Amparo Lazo y Villaflor, a 76-year-old woman and native of Sto. Domingo, Ilocos Sur, experienced a severe headache, vomiting, and subsequent cerebral hemorrhage on January 8, 1977.
The patient, already in a critical state due to a stroke, was rushed with relatives and boarders to the Polymedic General Hospital in Mandaluyong, Metro Manila.
Upon arrival at 7:45 PM, she was unconscious, on a stretcher, and displaying signs of cerebrovascular congestion, high blood pressure (200/100), and rapid pulse rate (100 per minute).
Initial medical interventions included oxygen inhalation, administration of dextrose, penicillin, solu-cortef, serpasil, decadron, and sodium bicarbonate; a vein was cut to attempt a reduction in blood pressure.

Due to the patient’s apnea, a team of doctors, including Doctor Emmanuel Favila and an anesthesiologist, Doctor Estacio, attended to her condition.
Around 8:30 PM, Doctor Estacio inserted an endotracheal tube into the patient’s mouth and windpipe to facilitate ventilation, securing it with adhesive tape (plaster) so as to help expel carbon dioxide and prevent “drowning.”

Angelo Umaguing, a 29-year-old janitor with a background as a member of the Bahala na Gang and known to have been working in the hospital since 1976, was present in the emergency room without any legitimate role in the patient’s care.
Initially, when Umaguing attempted to remove the plaster holding the tube, Doctor Estacio shooed him away.
Shortly after the medical staff had momentarily left the emergency room, and while the nurse’s attention was diverted, Umaguing deliberately returned and removed the endotracheal tube from the patient’s mouth.
His action was witnessed by the patient’s relatives—Jojo Cruz (grandson) and Adelaida Apostol (niece)—and corroborated by a nurse and other hospital personnel.

The removal of the tube resulted in the patient experiencing oral bleeding and a convulsive episode, as reported in witness testimonies.
Medical staff, including Doctor Ramon Sison (chief resident physician), subsequently reinserted the tube, yet the disruption affected the patient’s condition.
Following the incident, the patient was transferred to Cardinal Santos Hospital, where she later died from cardiorespiratory arrest compounded by cerebrovascular hemorrhage and hypertension.

Witness statements from various parties, including relatives and the nurse on duty, were recorded by the Mandaluyong police, establishing Umaguing’s culpability in removing the tube.
On January 12, 1977, a complaint for murder was filed by the chief investigator of the Mandaluyong police, and on January 20, 1977, the fiscal filed an information for murder against Umaguing before the Circuit Criminal Court at Pasig, Rizal.
The trial court initially convicted Umaguing of consummated murder, qualified by treachery and aggravated by abuse of superiority, nocturnity, disregard of old age, and ignominy; he was sentenced to death and ordered to pay damages to the heirs of Amparo Lazo.
In his defense, Umaguing claimed that he had been ordered by Doctor Sison to remove the endotracheal tube and other instruments, asserting that his act was in line with medical instructions to hasten a hopeless case.
However, testimony from Doctor Sison, among others, directly contradicted this claim, and the evidence pointed to a deliberate and malicious act rather than an accidental or commanded one.

Whether the removal of the endotracheal tube by Umaguing was the proximate cause of the patient’s subsequent death, given her critical condition prior to the incident.
Whether the patient’s underlying medical condition could have independently brought about her death notwithstanding the removal of the tube.

Whether Umaguing’s action in the emergency room—removing the tube—was accidental or carried out with a deliberate and malevolent intent.
Whether the alleged instruction by Doctor Sison to remove the tube could serve as a valid defense or excuse for committing what amounted to an act that endangered the patient’s life.

Whether Umaguing, as a janitor with no direct responsibility for patient care, had any legitimate reason to be in the emergency room monitoring the patient’s condition.
Whether his presence and actions constituted an ulterior motive aimed at hastening the patient’s death, thus amounting to criminal malice.