Case Digest (G.R. No. 213222) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In June 2009, Teresita Baltazar, a diabetic patient of Dr. Jade Malvar at Callang’s General Hospital, was referred for debridement to Echague District Hospital (EDH) due to financial constraints. Dr. Malvar consulted endocrinologist Dr. Cabucana De Guzman, who ordered insulin injections at 6 a.m., 12 n.n., 6 p.m., and 12 m.n., each to be preceded by a Random Blood Sugar (RBS) test. Night nurse Gigi Tomas endorsed the patient to Elsa De Vera (8 a.m.–4 p.m.), who administered insulin at 11:30 a.m. without an RBS check. After an uneventful debridement by Dr. Malvar and anesthesiologist Dr. Cabansag, De Vera’s shift ended, and Eleanor Reyno (4 p.m.–12 m.n.) took over. At 5:20 p.m., Reyno likewise injected insulin without conducting an RBS test. She also removed Teresita’s oxygen mask with temporary physician approval. Within hours, Teresita developed respiratory distress and excessive salivation, received emergency care, but died at 7 p.m. Her death certificate listed “Hypoglycemia Case Digest (G.R. No. 213222) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Antecedents
- Petitioners: Eleanor Reyno and Elsa De Vera, ward nurses at Echague District Hospital (EDH).
- Respondents: George Baltazar and Joel Baltazar, husband and son of diabetic patient Teresita Laurena Baltazar, referred to EDH by Dr. Jade Malvar for foot debridement.
- Medical Orders and Nurse Assignments
- Specialist Dr. Cabucana De Guzman ordered insulin at 6 a.m., 12 n.n., 6 p.m., and 12 m.n., each preceded by a Random Blood Sugar (RBS) test.
- Ward nurses on duty: Gigi Tomas (12 m.n.–8 a.m.), Elsa De Vera (8 a.m.–4 p.m.), and Eleanor Reyno (4 p.m.–12 m.n.).
- June 10, 2009 Events
- 11:30 a.m.: De Vera administered insulin without an RBS test; 12:00 n.n.–12:20 n.n.: Dr. Malvar and anesthesiologist Cabansag performed debridement without complication.
- 5:20 p.m.: Reyno administered insulin without an RBS test, removed oxygen mask; patient later had respiratory distress, salivation, received emergency measures, and was pronounced dead at 7:00 p.m.
- Procedural History
- George and Joel sued the province of Isabela, Dr. Ma. Cristina Ventura (OIC), Dr. Honorio Caramancion (resident), and nurses Reyno and De Vera for damages.
- RTC (Apr 29, 2015): Dismissed for lack of merit—no clear cause of death, no negligence proven.
- CA (June 28, 2016): Affirmed dismissal as to LGU, Drs. Ventura and Caramancion; held Reyno and De Vera jointly and severally liable under res ipsa loquitur; awarded damages. Denied nurses’ motion for reconsideration (Sept 20, 2016).
- Petition for review on certiorari to the Supreme Court followed.
Issues:
- Did the omission of a notice of hearing in the RTC motion for reconsideration violate procedural due process and render the RTC decision final and executory?
- Did the Court of Appeals err in applying the doctrine of res ipsa loquitur to hold nurses Reyno and De Vera liable for medical negligence causing Teresita’s death?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)