Case Digest (G.R. No. 158996)
Facts:
Spouses Fredelicto Flores (Deceased) and Felicisima Flores v. Spouses Dominador Pineda and Virginia Saclolo, et al., G.R. No. 158996, November 14, 2008, Supreme Court Second Division, Brion, J., writing for the Court.The petitioners are the married physicians Dr. Fredelicto A. Flores (anesthesiologist, deceased during these proceedings) and Dr. Felicisima Flores (obstetrician-gynecologist). The respondents are the heirs of Teresita Pineda (spouses Dominador Pineda and Virginia Saclolo and other children) and United Doctors Medical Center, Inc. (UDMC), the hospital where Teresita was treated.
On April 17, 1987 Teresita consulted Dr. Fredelicto for weakness, loss of appetite, polyuria, polydipsia and intermittent vaginal bleeding; the doctor suspected diabetes and advised follow-up. When symptoms persisted, Teresita returned on April 28, 1987 to the Floreses’ UDMC clinic. Dr. Fredelicto arranged admission and directed preparation for an “on call” dilatation and curettage (D&C) to be performed by his wife, Dr. Felicisima. Preliminary laboratory results (telephone report) were available before the operation at about 2:40 p.m., but the full laboratory report (including urinalysis showing 3+ glycosuria) was furnished only on April 29. The D&C was performed that afternoon; the procedure lasted some 10–15 minutes and the patient was returned to her room by 3:40 p.m.
Teresita’s condition deteriorated: an ultrasound on April 29 showed myoma uteri; urinalysis and further testing confirmed marked hyperglycemia consistent with Diabetes Mellitus Type II. She was transferred to intensive care and insulin was given only starting April 30; despite treatment she died on May 6, 1987. The death certificate listed immediate cause cardiorespiratory arrest, antecedent septicemic shock and ketoacidosis, with underlying Diabetes Mellitus II and contributing acute renal failure.
Believing the D&C was negligently performed and that the Floreses failed to recognize and address her diabetic state, the heirs sued the Floreses and UDMC in the Regional Trial Court (RTC), Civil Case No. SD-1233. The RTC found the doctors and hospital liable and awarded actual, moral and exemplary damages plus attorney’s fees and costs (RTC decision dated September 21, 1998). The Court of Appeals (CA) in CA G.R. CV No. 63234 affirmed with modification: it ordered joint and several payment of P400,000 moral damages, P100,000 exemplary damages, P36,000 actual/compensatory damages and deleted the award of attorney’s fees and costs (CA decision dated June 30, 2003). UDMC separately sought review of the CA decision, but this Court denied UDMC’s petition (Resolution dated August 28, 2006), leaving the hospital’s liability intact.
The Floreses filed a petition for review on certiorari under Ru...(Pro-only)
Issues:
- Did the petitioner spouses commit medical negligence in proceeding with the D&C despite indications of hyperglycemia and thereby cause Teresita Pineda’s death?
- Are the damages awarded by the courts below—actual (P36,000), moral (P400,000), exemplary (P100,000), death indemnity (P50,000), and attorney’s fees (P100,0...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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