Case Summary (G.R. No. 234851)
Key Dates
- Operation and injury: September 15, 2010
- Corrective surgery: November 19, 2010
- Civil complaint filed: November 10, 2015
- RTC joint orders denying motions to dismiss: May 6 and August 26, 2016
- Court of Appeals decision and resolution: June 16 and October 11, 2017
- Supreme Court decision: February 15, 2022
Applicable Law
- 1987 Philippine Constitution
- Rules of Court, Rule 45 (certiorari jurisdiction)
- Civil Code provisions on contracts (Arts. 1144–1145, 1170, 1173) and quasi-delicts (Arts. 1146, 2176)
Background of Medical Procedure and Alleged Negligence
The petitioner underwent an abdomino-pelvic sonogram and was diagnosed with cholelithiasis. Advised to have a laparoscopic cholecystectomy, he consented to a minimally invasive procedure. During surgery, the attending and principal surgeon (Dr. Uyloan) and the assisting surgeon (Dr. Ojeda) converted to open surgery without his prior approval, allegedly due to a punctured cystic artery. Subsequent testing revealed that they had transected and clipped the common bile duct instead of the cystic duct, causing bile leakage, severe pain, and necessitating corrective surgery. The petitioner claimed breach of professional duties, resulting in damages.
Procedural History Before the RTC
The petitioner filed a complaint for damages under Arts. 1170 and 1173 of the Civil Code. Respondents moved to dismiss on grounds of prescription (four-year period for quasi-delicts), forum shopping, and lack of jurisdiction. The Regional Trial Court denied the motions, ruling that prescription is an evidentiary issue not resolvable on a motion to dismiss and that civil, criminal, and administrative actions involved distinct causes of action. Motions for reconsideration were likewise denied, prompting Dr. Uyloan to petition the Court of Appeals.
Court of Appeals’ Ruling on Prescription
The Court of Appeals granted certiorari, finding that the petitioner’s cause of action was based on medical negligence—a quasi-delict with a four-year prescription under Art. 1146. Since the complaint was filed more than five years after the operation, the action was time-barred. The CA held that the trial court had gravely abused its discretion in denying the motion to dismiss and dismissed the complaint.
Issue Before the Supreme Court
Whether the Court of Appeals committed reversible error in ruling that the trial court gravely abused its discretion by refusing to dismiss the complaint as prescribed.
Petitioner’s Argument for Contractual Basis and Longer Prescription
The petitioner contended that the physician-patient and patient-hospital relationships are contractual, invoking Arts. 1144 (ten-year prescription for written contracts) or 1145 (six-year prescription for oral contracts) rather than the four-year period for quasi-delicts. He cited foreign cases recognizing contractual claims for medical malpractice and argued that contract and quasi-delict theories can coexist, making prescription a matter unsuited for dismissal without full trial.
Respondents’ Argument on Quasi-Delict Nature of Claim
Dr. Uyloan asserted that Philippine jurisprudence uniformly treats medical malpractice as a form of quasi-delict under Art. 2176, requiring proof of duty, breach, injury, and causation. The complaint’s allegations of negligence and lack of any express promise to achieve a specific result supported the four-year prescription. The absence of an express contractual warranty of success precluded a contract-based malpractice claim.
Supreme Court’s Analysis on Nature of Medical Malpractice Claims
The Court reiterated that medical negligence claims in the Philippines are governed by the law on quasi-delicts (Art. 2176) and not by contract, unless an express promise of result exists. A physician-patient relationship gives rise to a duty of care, but abs
...continue readingCase Syllabus (G.R. No. 234851)
Facts
- On September 13, 2010, petitioner underwent an abdomino-pelvic sonogram; Dr. Uyloan diagnosed cholelithiasis and advised laparoscopic cholecystectomy.
- Petitioner consented to a minimally invasive procedure at AHMC; on September 15, 2010, Dr. Uyloan (principal surgeon) and Dr. Ojeda (assistant) performed an open cholecystectomy without petitioner’s prior approval.
- During surgery, petitioner sustained a punctured cystic artery, lost substantial blood, and required transfusion.
- Discharged on September 19, 2010, with release forms stating “good condition” and “recovered,” petitioner experienced vomiting, severe abdominal pain, and continuous bile leakage.
- Follow-up revealed persistent bile leak; Dr. Uyloan attributed symptoms to normal postoperative course and advised further imaging.
- Subsequent tests at another hospital showed transection and clipping of the common bile duct instead of the cystic duct, causing bile accumulation and necessitating corrective surgery on November 19, 2010.
- Petitioner incurred medical expenses totaling PHP 2,600,000.00 and alleged breach of professional duties under an implied medical contract and quasi-delict against the doctors and vicarious liability of AHMC.
Procedural History
- November 10, 2015: Petitioner filed a complaint for damages under Articles 1170 and 1173 of the Civil Code against Dr. Uyloan, Dr. Ojeda, and AHMC.
- Defendants moved to dismiss on grounds of prescription (four-year period for quasi-delict per Art. 1146), forum shopping, and lack of jurisdiction.
- May 6, 2016 & August 26, 2016: RTC Branch 198 (Las Piñas City) denied the motions, ruling prescription is evidentiary and cannot be resolved on a motion to dismiss; no forum shopping found.
- Defendants elevated to petition for certiorari before the CA.
- June 16, 2017: CA reversed the RTC, holding the cause of action was medical negligence (quasi-delict), time-barred by prescription, and dismissed the complaint.
- October 11, 2017: CA denied petitioner’s motion for reconsideration.
- Petitioner filed a petition for review under Rule 45 before the Supreme Court.