Case Digest (G.R. No. 126297) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Professional Services, Inc. v. Natividad and Enrique Agana (G.R. Nos. 126297, 126467 & 127590, January 31, 2007), respondent Natividad Agana was admitted to Medical City General Hospital (owned by petitioner Professional Services, Inc. or PSI) on April 4, 1984, for sigmoid cancer. On April 11, 1984, Dr. Miguel Ampil (petitioner in G.R. No. 127590) performed an anterior resection, and finding ovarian involvement, secured consent from her husband, Enrique Agana, to have Dr. Juan Fuentes (respondent in G.R. No. 126467) perform a hysterectomy. The post-operative nurse’s record noted “sponge count lacking 2… announced to surgeon… search done but to no avail… continue for closure,” yet the incision was closed without informing the patient. On May 1984, Natividad sought treatment in the United States, where she was declared cancer‐free but remained in pain. Upon return, one gauze was manually removed at home; another was found in her vagina by Dr. Ramon Gutierrez, which had caused a Case Digest (G.R. No. 126297) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties, Claims and Proceedings
- On November 12, 1984, Natividad Agana and her husband Enrique filed Civil Case No. Q-43322 before the RTC, Branch 96, Quezon City, against Professional Services, Inc. (PSI), Dr. Miguel Ampil, and Dr. Juan Fuentes for negligence and malpractice.
- Natividad died on February 16, 1986, and was substituted by her children. Enrique separately filed an administrative complaint before the PRC Board of Medicine against Drs. Ampil and Fuentes (Administrative Case No. 1690).
- Medical Treatment and Alleged Negligence
- April 4–11, 1984 – Natividad was admitted to Medical City Hospital for bowel obstruction and bloody discharge; Dr. Ampil diagnosed sigmoid cancer.
- Dr. Ampil performed anterior resection; finding ovarian spread, he obtained Enrique’s consent for Dr. Fuentes to perform a hysterectomy.
- Attending nurses’ operation record noted “sponge count lacking 2 … search done but to no avail … continue for closure.”
- April 24–May 1984 – Patient discharged; complained of severe pain attributed by both doctors to normal post-operative effects; Dr. Ampil advised oncologic follow-up.
- May–August 1984 – Patient sought treatment in the U.S.; declared cancer-free after four months; returned to the Philippines still in pain.
- September–October 1984 – A piece of gauze protruded from patient’s vagina; Dr. Ampil manually extracted it but pain persisted; at Polymedic Hospital, a second gauze and an infected recto-vaginal fistula were found, necessitating another operation in October 1984.
- Trial and Intermediate Decisions
- March 17, 1993 – RTC rendered judgment for plaintiffs, holding PSI, Dr. Ampil, and Dr. Fuentes jointly and severally liable, and awarding actual, moral, exemplary damages, attorney’s fees and interest.
- May 11, 1993 – Partial execution ordered; properties of Dr. Ampil levied and sold. The Aganas later sought execution against PSI and Dr. Fuentes.
- September 21, 1993 – RTC issued alias writ of execution against PSI and Dr. Fuentes; Dr. Fuentes obtained injunctive relief from the CA (CA‐G.R. SP No. 32198).
- September 6, 1996 – CA in CA-G.R. CV No. 42062 and SP No. 32198 affirmed RTC decision but:
- Dismissed the case against Dr. Fuentes.
- Held that Dr. Ampil must reimburse PSI for any amounts paid to plaintiffs.
- December 19, 1996 – CA denied Dr. Ampil’s motion for reconsideration.
Issues:
- Whether the CA erred in holding Dr. Ampil liable for negligence and malpractice.
- Whether the CA erred in absolving Dr. Fuentes of liability.
- Whether PSI may be held solidarily liable for Dr. Ampil’s negligence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)