Case Digest (G.R. No. 192123) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On May 17, 1995, at the Ospital ng Maynila in Manila, three-year-old Gerald Albert Gercayo, born June 2, 1992 with an imperforate anus, underwent a pull-through operation to restore anal function. The surgical team was led by Dr. Leandro Resurreccion, assisted by Drs. Joselito Luceño, Donatella Valeña, and Joseph Tibio; anesthesia was provided by Drs. Marichu Abella, Arnel Razon, and petitioner Dr. Fernando P. Solidum. During surgery, Gerald developed bradycardia and resultant hypoxic encephalopathy, fell into a coma for two weeks, and emerged permanently blind, deaf, and paralyzed. His mother, Ma. Luz Gercayo, filed a reckless imprudence complaint against the attending physicians; the City Prosecutor charged only Dr. Solidum for allegedly administering “100% halothane” and failing to monitor anesthesia, causing cardiac arrest and serious injury. The case was transferred from the Metropolitan Trial Court to the Regional Trial Court (RTC) as Criminal Case No. 01-190889. On July 1 Case Digest (G.R. No. 192123) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Patient’s Background and Pre-Operative History
- Gerald Albert Gercayo born on June 2, 1992 with imperforate anus; underwent colostomy at two days old.
- On May 17, 1995 (age 3), admitted to Ospital ng Maynila for pull-through operation to restore anal opening.
- Operative Team and Intraoperative Events
- Surgical team led by Dr. Leandro Resurreccion; assisted by Drs. Luceño, Valeña, Tibio; anesthesiologists Drs. Abella, Razon, Solidum.
- During surgery: Gerald developed bradycardia, went into coma (2 weeks), suffered hypoxic encephalopathy; resulted in permanent loss of sight, hearing, motor function.
- Dispute over anesthetic administration: City Prosecutor alleged 100% halothane overdose; defense claimed only 1% halothane with pure oxygen delivered by anesthesia machine; attempted resuscitation with atropine, epinephrine, CPR; CT scan confirmed hypoxia.
- Procedural History
- Mother filed complaint for reckless imprudence resulting in serious physical injuries against attending physicians; information ultimately charged only Dr. Solidum.
- RTC (Family Court) found Dr. Solidum guilty of reckless imprudence, sentenced to arresto mayor to prision correccional, ordered moral/exemplary damages jointly with hospital.
- CA affirmed under doctrine of res ipsa loquitur; denied petitioner’s motion for reconsideration (May 7, 2010).
- Dr. Solidum appealed by certiorari to the Supreme Court (G.R. No. 192123).
Issues:
- Whether the doctrine of res ipsa loquitur was properly applied to find negligence in the administration of anesthesia.
- Whether Dr. Solidum was criminally liable for reckless imprudence resulting in serious physical injuries.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)