Case Digest (G.R. No. 126297) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Professional Services, Inc. v. Court of Appeals (G.R. Nos. 126297, 126467 & 127590; February 2, 2010), petitioner Professional Services, Inc. (PSI) was impleaded along with Dr. Miguel Ampil and Dr. Juan Fuentes by Enrique Agana and Natividad Agana (later substituted by her heirs) for damages arising from a surgical operation on April 11, 1984 at Medical City General Hospital in Quezon City. Plaintiffs alleged that after abdominal surgery, two gauzes were left inside Mrs. Agana, causing chronic injury and pain. The complaint was filed before the Regional Trial Court (RTC) of Quezon City, Branch 96, which, by decision dated March 17, 1993, found PSI solidarily liable with both doctors. On appeal, the Court of Appeals (CA), in a September 6, 1996 decision, exonerated Dr. Fuentes but affirmed the liability of Dr. Ampil and PSI (subject to reimbursement rights). The Supreme Court’s First Division, in a decision of January 31, 2007, and a resolution of February 11, 2008, denied PSI Case Digest (G.R. No. 126297) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Procedural Posture
- Professional Services, Inc. (PSI) – owner/operator of Medical City General Hospital; impleaded as defendant.
- Enrique Agana and Natividad Agana (later substituted by her heirs) – plaintiffs alleging damages from retained gauzes after surgery.
- Dr. Miguel Ampil and Dr. Juan Fuentes – consultants who performed the surgery.
- Manila Medical Services, Inc. (MMSI), Asian Hospital, Inc. (AHI), and Private Hospital Association of the Philippines (PHAP) – intervenors arguing the decision’s effect on private hospitals.
- Procedural History
- RTC (Quezon City, Branch 96) decision on March 17, 1993 – held PSI and Dr. Ampil solidarily liable; Dr. Fuentes also held liable.
- CA decision on September 6, 1996 – absolved Dr. Fuentes; affirmed PSI and Dr. Ampil’s liability (subject to PSI’s right to reimburse Dr. Ampil).
- SC decision on January 31, 2007 (513 SCRA 478) – affirmed CA; resolution on February 11, 2008 (544 SCRA 170) denied reconsideration.
- PSI filed its second motion for reconsideration; MMSI, AHI, PHAP moved to intervene; matter referred to SC En Banc; oral arguments held March 4, 2009.
- Incident and Core Allegations
- On April 11, 1984, Drs. Ampil and Fuentes performed surgery on Natividad Agana at Medical City; two gauzes were inadvertently left in her body.
- Plaintiffs alleged that PSI, as hospital operator, was vicariously and directly liable for the doctors’ negligence.
- PSI denied an employment relationship with Dr. Ampil, denying control over consultants, and contested corporate negligence.
Issues:
- Whether an employer-employee relationship existed between PSI and Dr. Ampil under the “control test.”
- Whether PSI is vicariously liable under ostensible agency for Dr. Ampil’s negligence.
- Whether PSI is directly liable under the doctrine of corporate negligence for failing to investigate and address the missing gauzes.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)