Case Summary (G.R. No. 271081)
Key Dates and Applicable Law
- Medical examination by petitioner: January 10–11, 2008 (Certification valid until April 11, 2008)
- Saudi re-examinations: March 24, 2008 and April 28, 2008 (positive for HCV)
- Supreme Court decision: December 4, 2017
- Governing constitution: 1987 Philippine Constitution
- Governing statute: Civil Code, Article 2176 (quasi-delict)
Factual Background
Respondent referred Raguindin to petitioner for a GAMCA-mandated medical clearance. Petitioner’s Medical Report of January 11, 2008 declared him “fit for employment.” Respondent then processed deployment, incurring ₱84,373.41 in expenses. Subsequent Saudi health checks in late March and April 2008 revealed HCV positivity, prompting Raguindin’s repatriation.
Procedural History
Respondent sued for recovery of deployment costs and damages before the Metropolitan Trial Court (MeTC). The MeTC awarded actual damages, attorney’s fees, and costs. The Regional Trial Court affirmed. On appeal, the Court of Appeals deleted actual damages but granted ₱50,000 temperate damages. Petitioner filed a Rule 45 petition before the Supreme Court.
Issue
Whether petitioner was negligent in issuing the Medical Report and thus liable for damages under Article 2176 of the Civil Code.
Scope of Review
Under Rule 45, the Supreme Court reviews only legal questions, except when factual inferences are manifestly unsupported or conclusions lack evidentiary basis—a recognized exception present here.
Legal Basis of Liability
Liability for negligent certification arises under Article 2176 (quasi-delict), which requires proof of (1) wrongful act or omission, (2) fault or negligence, (3) damage, (4) causation, and (5) absence of contractual relation. Articles 19–21 of the Civil Code are inapplicable because no breach of specific law or pre-existing contract was alleged.
Standard of Negligence and Burden of Proof
Negligence is the failure to exercise the care of an ordinarily prudent person. It must be established by a preponderance of evidence. The party alleging negligence bears this burden; negligence is never presumed.
Analysis on Negligence
Respondent relied solely on foreign medical findings dated two months after petitioner’s examination. Such post-deployment tests do not prove that petitioner breached its duty on January 11, 2008. Given HCV’s incubation period (2 weeks–6 months) and its asymptomatic acute phase, infection could have occurred after petitioner’s clearance. Respondent offered no evidence of procedural lapses or warning signs at the time of the initial examination.
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Facts
- LWV Construction Corporation (“respondent”) recruits Filipino workers for deployment to Saudi Arabia.
- St. Martin Polyclinic, Inc. (“petitioner”) is accredited by the Gulf Cooperative Council Approved Medical Centers Association (GAMCA) to perform pre‐deployment medical examinations.
- On January 10, 2008, respondent referred Jonathan V. Raguindin to petitioner for his GAMCA‐mandated medical exam.
- Petitioner conducted the examinations and on January 11, 2008 issued a Medical Report declaring Raguindin “fit for employment.”
- Relying on this certification, respondent deployed Raguindin and incurred expenses amounting to ₱84,373.41.
- On March 24, 2008, a Saudi Arabian medical examination by the General Care Dispensary tested Raguindin positive for hepatitis C virus (HCV).
- The Saudi Ministry of Health ordered a re‐examination on April 28, 2008; the results remained positive for HCV, as shown in a Certification dated April 28, 2008 and an undated HCV Confirmatory Test Report.
- Raguindin was subsequently repatriated to the Philippines due to the positive HCV finding.
Procedural History
- Respondent filed a complaint in the Metropolitan Trial Court (MeTC) of Mandaluyong City (Branch 60), claiming petitioner’s recklessness in issuing the “fit for employment” report and praying for ₱84,373.41 in actual damages.
- Petitioner’s Answer and Counterclaim denied liability, arguing lack of privity, lack of jurisdiction, prematurity, and expiration of the Medical Report on April 11, 2008.
- MeTC Decision (Dec. 17, 2010): Held jurisdiction proper; found petitioner negligent; awarded respondent ₱84,373.41 actual damages, ₱20,000 attorney’s fees, and costs.
- Regional Trial Court (RTC) Decision (Dec. 15, 2011): Dismissed petitioner’s appeal; affirmed MeTC Decision in entirety; denied reconsideration (May 25, 2012).
- Court of Appeals (CA) Decision (July 11, 2014): Affirmed