Case Digest (G.R. No. 217426) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In St. Martin Polyclinic, Inc. v. LWV Construction Corporation, respondent LWV Construction Corporation, a licensed recruiter of Filipino workers to Saudi Arabia, referred Jonathan V. Raguindin to petitioner St. Martin Polyclinic, Inc. on January 10, 2008 for a pre‐deployment medical examination as required by the Gulf Cooperative Council Approved Medical Centers Association (GAMCA). On January 11, 2008, petitioner issued a Medical Report declaring Raguindin “fit for employment,” prompting respondent to deploy him abroad and spend ₱84,373.41 on recruitment and processing. On March 24 and April 28, 2008, the General Care Dispensary and the Saudi Ministry of Health conducted exams in Riyadh, both finding Raguindin positive for the hepatitis C virus (HCV). He was subsequently repatriated. Claiming damage from petitioner’s alleged negligent certification, respondent sued in the Metropolitan Trial Court (MeTC) of Mandaluyong City for recovery of its expenses. The MeTC ruled for respo Case Digest (G.R. No. 217426) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Context
- LWV Construction Corporation (Respondent) is engaged in recruiting Filipino workers for deployment to Saudi Arabia.
- St. Martin Polyclinic, Inc. (Petitioner) is a GAMCA-accredited medical center authorized to conduct pre-deployment medical examinations.
- Medical Examination and Deployment
- On January 10–11, 2008, Respondent referred applicant Jonathan V. Raguindin to Petitioner; Petitioner issued a Medical Report dated January 11, 2008, declaring him “fit for employment.”
- Respondent thereafter deployed Raguindin to Saudi Arabia, incurring approximately ₱84,373.41 in deployment expenses.
- Subsequent HCV Findings and Repatriation
- On March 24, 2008, the General Care Dispensary in Saudi Arabia tested Raguindin and found him positive for hepatitis C virus (HCV); a re-examination on April 28, 2008 confirmed the result.
- Based on these findings, the Saudi Ministry of Health required Raguindin’s repatriation to the Philippines.
- Litigation History
- Respondent filed a complaint before the Metropolitan Trial Court (MeTC) seeking actual damages of ₱84,373.41 and attorney’s fees, alleging Petitioner’s reckless issuance of the “fit for employment” report.
- Petitioner denied liability, raising defenses of lack of privity, lack of jurisdiction, prematurity, and expiration of the Medical Report.
- The MeTC awarded actual damages; the Regional Trial Court (RTC) affirmed; the Court of Appeals (CA) modified the award to temperate damages of ₱50,000. Petitioner elevated the case to the Supreme Court.
Issues:
- Whether Petitioner was negligent in issuing the Medical Report declaring Raguindin “fit for employment.”
- Whether Respondent sufficiently proved negligence and causation to hold Petitioner liable for damages.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)