Case Summary (G.R. No. 227775)
Post-Operative Care and Nursing Duties
After an uncomplicated debridement ending at 12:20 n.n., Teresita was placed under ward care. De Vera, on duty until 4 p.m., administered insulin at 11:30 a.m. Reyno, on duty thereafter, administered a subsequent insulin dose at 5:20 p.m. Neither nurse documented an RBS test prior to these injections, and Teresita was not fed post-procedure.
Sudden Deterioration and Emergency Response
Shortly after removing and then reinstating an oxygen mask, Teresita developed breathing difficulty and salivation. Nurses contacted Dr. Malvar, administered “fifty-fifty intravenous,” and sought resident Dr. Caramancion’s help. Epinephrine was given when she became unresponsive, but Teresita was pronounced dead at 7 p.m.
Procedural History before the RTC
George and Joel sued EDH personnel, Drs. Malvar, De Guzman, Cabansag, Caramancion, nurses Reyno and De Vera, Dr. Ventura, and the LGU of Isabela for damages. The RTC, finding no clear cause of death without autopsy and no negligence by staff, dismissed the complaint and denied reconsideration.
Court of Appeals’ Application of Res Ipsa Loquitur
On appeal, the CA relieved Isabela, Dr. Ventura, and Dr. Caramancion from liability, but held Reyno and De Vera jointly and severally liable. Relying on res ipsa loquitur, the CA reasoned that death within 24 hours of a minor procedure, without obvious cause, and under exclusive control of the nurses, warranted a presumption of negligence due to failure to perform RBS tests before insulin injections.
Petitioners’ Procedural Due Process Challenge
Reyno and De Vera argued that the CA should not have considered George and Joel’s motion for reconsideration at the RTC because it lacked a notice of hearing, rendering the RTC decision final. They contended that this procedural defect deprived them of due process and the right to appeal.
Supreme Court’s Ruling on Notice of Hearing
The Supreme Court affirmed the CA, applying Jehan Shipping Corp. v. NFA. It held that the absence of a notice of hearing does not invalidate a motion for reconsideration if the opposing party was given the opportunity to study the motion and meaningfully oppose it. Since petitioners filed oppositions at both RTC and CA levels, they were not prejudiced, and procedural due process was satisfied under Section 5, Rule 15, and its 2020 amendment.
Doctrine of Res Ipsa Loquitur in Medical Negligence
Res ipsa loquitur allows inference of negligence where (1) the accident ordinarily does not occur absent negligence, (2) the instrumentality was under the defendant’s exclusive control, and (3) the injured did not contribute. In medical cases, it dispenses with expert testimony where the injury itself evidences deviation from proper care.
Application to the Present Case
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Antecedents
• George Baltazar and Joel Baltazar are husband and son, respectively, of diabetic patient Teresita Laurena Baltazar.
• Teresita was referred by Dr. Jade P. Malvar at Callang’s General Hospital for a foot wound; advised to undergo minor debridement.
• Due to financial constraints, Dr. Malvar ordered her transfer to Echague District Hospital (EDH) on June 9, 2009, for surgery the next day.
• Dr. Ma. Cabucana De Guzman instructed that Teresita receive insulin at 6 a.m., 12 n.n., 6 p.m., and 12 m.n., each preceded by a Random Blood Sugar (RBS) test.
• Nurses on duty: Gigi Tomas (12 m.n.–8 a.m.), Elsa De Vera (8 a.m.–4 p.m.), and Eleanor Reyno (4 p.m.–12 m.n.).
Facts of the Case
• June 10, 2009, 10:30 a.m.: George and Joel visit; patient in high spirits.
• 11:15 a.m.: Tomas endorses Teresita to De Vera; 11:30 a.m.: De Vera administers insulin without recorded RBS.
• 12:20 n.n.: Dr. Malvar and anesthesiologist Dr. Cabansag perform uncomplicated debridement.
• 4:00 p.m.: De Vera ends shift; Reyno assumes duty.
• 5:20 p.m.: Reyno administers second insulin dose without prior RBS; removes oxygen mask after securing doctor’s clearance.
• Patient’s breathing worsens; oxygen mask returned; Dr. Malvar orders “fifty-fifty IV”; Dr. Caramancion gives epinephrine.
• 7:00 p.m.: Teresita pronounced dead—death certificate cites metabolic encephalopathy versus myocardial infarction, underlying probable hypoglycemia.
Procedural History
• July 7, 2010: George and Joel sue Province of Isabela (LGU), Dr. Ventura (OIC of EDH), Dr. Caramancion, and nurses Reyno and De Vera for negligence.
• April 29, 2015 (RTC): Complaint dismissed—cause of death not established (no autopsy); no negligence by EDH staff; nurses and LGU exculpated.
• July 30, 2015: Motion for reconsi