Title
Richmon vs. Anchuelo
Case
G.R. No. 1785
Decision Date
Jul 17, 1905
A doctor sued a blind patient for payment after unsuccessful treatment; court ruled in favor of the doctor, excluding hearsay evidence supporting the patient's claim.

Case Digest (G.R. No. 103119)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Plaintiff Shannon Richmond, a doctor, was employed by defendant Francisco Anchuealo, who was blind.
    • The employment involved treating the defendant’s eyes.
    • The plaintiff rendered his medical services, which ultimately did not result in a cure.
  • Nature of the Contract and Dispute
    • The central issue revolved around the interpretation of the contract between the parties.
    • The plaintiff’s version of the contract:
      • He claimed that he was entitled to 200 pesos regardless of the outcome.
      • Additionally, if he effected a cure, he was to receive an extra 500 pesos.
    • The defendant’s version of the contract:
      • He maintained that the plaintiff was to be paid 200 pesos if a cure was effected.
      • If the treatment was unsuccessful and no cure was effected, the plaintiff was to receive nothing.
  • Presentation of Evidence and Trial Proceedings
    • The evidence was primarily testimonial, and the trial focused on the conflicting versions of the agreement.
    • The defendant introduced a witness, Jose Pastor, who was called to testify about statements allegedly made by the plaintiff.
      • The witness testified that the defendant had remarked, on returning from the plaintiff’s office, that the plaintiff agreed to treat him for 200 pesos and would not charge in case of failure.
      • Notably, Pastor did not testify about any direct statements made by the plaintiff; he merely recounted what the defendant purportedly said the plaintiff had stated.
    • The trial judge excluded this evidence based on its inadmissibility under the hearsay rules stipulated in section 276 of the Code of Civil Procedure.
    • The court below ruled in favor of the plaintiff, with findings supported by the evidence presented.

Issues:

  • Determination of the True Contractual Obligation
    • What exactly were the terms agreed upon by the parties regarding payment for the medical services provided?
    • Whether the plaintiff was entitled to receive 200 pesos irrespective of the treatment outcome or only upon a successful cure.
  • Admissibility of Evidence
    • The propriety of admitting the testimony of a witness (Jose Pastor) who recounted statements that were not directly observed from the plaintiff.
    • Whether the evidence should be excluded pursuant to section 276 of the Code of Civil Procedure, given its nature as hearsay.
  • Evaluation of Testimonial Contradictions
    • Resolving the conflicting narratives regarding the agreed fee between the plaintiff and defendant.
    • Determining whether the trial evidence sufficiently supported the plaintiff’s claim over the defendant’s assertion.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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