G.R. No. 230657 - Magno vs. People

Teresita Pineda, a 51-year-old unmarried woman from Sto. Domingo, Nueva Ecija, consulted her townmate physician, Dr. Fredelicto Flores, on April 17, 1987, complaining of general body weakness, loss of appetite, frequent urination and thirst, and intermittent vaginal bleeding.
Dr. Fredelicto suspected diabetes mellitus and advised her to return or go to the United Doctors Medical Center (UDMC) for further examination. Teresita did not return immediately but consulted again on April 28, 1987, at UDMC with her sister Lucena Pineda, due to persistent symptoms.

Upon arrival at the UDMC clinic, Teresita was weak and had to lie down on a couch. Dr. Fredelicto ordered her admission and directed for an "on call" dilatation and curettage (D&C) operation to be performed by his wife, Dr. Felicisima Flores, an obstetrician-gynecologist.
Laboratory tests were ordered including blood sugar and complete blood count, but only preliminary results were available before the operation: blood sugar was 10.67 mmol/l (random) and hemoglobin was 109 g/l (below normal).
The D&C operation was performed that same day at around 2:40 p.m., lasting 10–15 minutes, with Dr. Fredelicto administering general anesthesia.

On April 29, 1987, complete laboratory results indicated a 3+ sugar level in urine, strongly indicative of diabetes mellitus. An ultrasound showed an enlarged uterus and myoma uteri.
Despite these findings, Teresita was advised that she could recover at home, but she opted for hospital confinement.
Her condition deteriorated on April 30, 1987; she experienced breathing difficulties and was admitted to the ICU under the care of internist Dr. Amado Jorge. Insulin treatment was started but possibly too late.
Teresita died on May 6, 1987 due to complications attributed to diabetes—cardiorespiratory arrest, septicemic shock, ketoacidosis, and acute renal failure as per death certificate.

Teresita’s heirs, the respondents (Spouses Dominador Pineda and Virginia Saclolo, and other siblings), filed a medical negligence suit against Drs. Fredelicto and Felicisima Flores and UDMC before the Regional Trial Court (RTC) of Nueva Ecija.
The RTC ruled in favor of the heirs, awarding actual, moral, and exemplary damages, attorney’s fees, and costs of suit.
The Court of Appeals (CA) affirmed with modifications: moral damages of ₱400,000; exemplary damages of ₱100,000; actual damages of ₱36,000; and deleted attorney's fees and costs of suit.
The petitioner spouses filed a petition for certiorari challenging the findings of negligence, damages awarded, and costs, claiming due diligence and proper medical care in their management of Teresita’s case.

Whether or not the petitioner spouses were negligent in proceeding with the D&C operation despite Teresita’s condition and laboratory results indicating possible diabetes mellitus.

Whether the decision to conduct the D&C operation amounted to a breach of the standard of care expected from medical professionals under the circumstances.

Whether the awards of actual, moral, exemplary damages, attorney’s fees, and death indemnity were proper.