Case Digest (G.R. No. 130547)
Facts:
In Reyes v. Sisters of Mercy Hospital, G.R. No. 130547, decided October 3, 2000 under the 1987 Constitution, petitioners Leah Alesna Reyes and her children, Rose Nahdja, Johnny, Lloyd, and Kristine, all surnamed Reyes, sued the Sisters of Mercy Hospital, Sister Rose Palacio (directress), Dr. Marlyn Rico and Dr. Marvie Blanes for damages arising from the death of petitioners’ husband and father, Jorge Reyes. Jorge had suffered recurring fever with chills for five days and was brought to the Mercy Community Clinic in Cebu City on January 8, 1987, where Dr. Rico ordered a Widal test and, on a positive result, initiated typhoid fever treatment. That evening Dr. Blanes continued care, conducted a compatibility test for chloromycetin, and administered two intravenous doses of 500 mg within a three-hour interval. Jorge developed high fever, convulsions, cyanosis and died at 2:00 a.m. on January 9, 1987. An autopsy performed by Dr. Apolinar Vacalares showed a normal gastrointestinal traCase Digest (G.R. No. 130547)
Facts:
- Parties and Background
- Petitioners: Leah Alesna Reyes (widow of Jorge Reyes) and their children Rose Nahdja, Johnny, Lloyd, and Kristine Reyes, represented by Leah A. Reyes.
- Respondents: Sisters of Mercy Hospital (Mercy Community Clinic), Sister Rose Palacio (directress), Dr. Marlyn Rico (resident/admitting physician), Dr. Marvie Blanes, and formerly nurse Josephine Pagente.
- Procedural posture: Complaint filed June 3, 1987 in RTC Cebu City; amended complaint added Mercy Community Clinic, dropped Pagente; trial court dismissed; CA affirmed; petition to SC on October 3, 2000.
- Medical Treatment and Patient’s Death
- Jorge Reyes had five days of recurring fever with chills unrelieved by home medication; admitted January 8, 1987 to Mercy Community Clinic.
- Dr. Marlyn Rico performed physical exam (conscious, oriented, respiratory distress), noted local typhoid prevalence (15–20 monthly), ordered Widal test plus blood count, urinalysis, stool exam, malarial smear; Widal test returned positive (1:320).
- Dr. Rico’s shift ended; she indorsed patient to Dr. Marvie Blanes around 6 p.m.; Dr. Blanes repeated exam, ordered chloromycetin skin‐test (negative) and first 500 mg IV dose at 9 p.m., second dose before midnight.
- Around 1 a.m. January 9 Jorge developed hyperpyrexia (41 °C), chills, respiratory distress, nausea, vomiting, convulsions; treated with oxygen, suction, hydrocortisone, later diazepam; patient lapsed into cyanosis and died at 2 a.m. Cause of death: “Ventricular Arrhythmia Secondary to Hyperpyrexia and typhoid fever.”
- Trial and Evidence
- Trial court issues agreed: (1) negligence as cause of death; (2) clinic’s negligence in hiring; (3) entitlement to damages.
- Petitioners’ expert: Dr. Apolinar Vacalares (chief pathologist) performed autopsy—no gross intestinal lesions, concluded death by “shock undetermined” (allergic reaction or chloromycetin overdose).
- Respondents’ experts:
- Dr. Peter Gotiong (infectious diseases specialist) testified Widal test ratio 1:320 and patient history reasonably support typhoid diagnosis; chloromycetin is drug of choice; complications (myocarditis, meningitis) explain rapid decline; brain exam needed to confirm meningitis.
- Dr. Ibarra Panopio (pathologist) confirmed Widal test acceptability, hyperplasia in Peyer’s patches may be microscopic, 1:320 ratio sufficient, drug dosage within standard.
- Lower Courts’ Decisions
- RTC (1991): dismissed complaint and respondents’ counterclaim; found no negligent act or breach of standard care.
- CA (1997): affirmed; rejected res ipsa loquitur argument; upheld expert findings and standard practices; denied alleged lower standard of care in Iligan City.
Issues:
- Stipulated Trial Issues
- Was Jorge Reyes’s death caused by respondents’ negligence, carelessness, imprudence, or lack of skill?
- Was Mercy Community Clinic negligent in hiring its personnel?
- Were petitioners or respondents entitled to damages?
- Appellate Contentions
- Applicability of res ipsa loquitur to dispense with expert testimony.
- Whether CA erred in assuming lower standard of medical practice in Iligan City.
- Whether a lesser standard of care and diligence was applied to respondent doctors.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)