De Vera v. Baltazar

 

De Vera v. Baltazar

G.R. No. 227775

October 10, 2022

 

FACTS:

Teresita Laurena Baltazar (Teresita), a diabetic patient, was referred to a government hospital for a wound debridement procedure. The nurses on duty, including petitioners Eleanor Reyno (Reyno) and Elsa De Vera (De Vera), were responsible for administering insulin and following specific instructions from Dr. Cabucana De Guzman. Alleged negligence occurred when the nurses administered insulin without the required Random Blood Sugar (RBS) test and removed Teresita's oxygen mask against doctor's orders, leading to Teresita's deteriorating health and eventual death. The heirs of Teresita filed a damages case against the hospital staff, asserting medical negligence as the cause of death. The RTC dismissed the case for lack of merit and concluded that the cause of death was not clearly established, and there was no negligence on the part of the hospital staff. The CA partially granted the appeal, relieving some defendants from liability but held nurses Reyno and De Vera jointly and severally liable for damages based on the doctrine of res ipsa loquitur, emphasizing the nurses' negligence as the proximate cause of Teresita's death.

ISSUE:

Whether or not the doctrine of res ipsa loquitur should be applied.

HELD:

Yes, the doctrine of res ipsa loquitur should be applied. Res ipsa loquitur has following elements: (1) The accident was of such character as to warrant an inference that it would not have happened except for the defendant's negligence; (2) The accident must have been caused by an agency or instrumentality within the exclusive management or control of the person charged with the negligence complained of; and (3) The accident must not have been due to any voluntary action or contribution on the part of the person injured. Further, the application of res ipsa loquitur in medical negligence cases involves a question of law, allowing a plaintiff to establish a nexus between a specific act or omission and the injury without expert medical testimony. In this case, all elements for applying res ipsa loquitur were present. The subsequent deterioration of Teresita's health occurred under the exclusive care and control of the petitioners, who were responsible for administering medicines and treatments as per doctor's orders. Despite the minor nature of the operation, the petitioners were negligent in their duties, particularly in injecting insulin without the necessary blood sugar test, leading to Teresita's hypoglycemia and eventual death. Moreover, the court emphasized the relevance of Teresita's Certificate of Death as prima facie evidence and relied on the testimony of Dr. Malvar, Teresita's personal physician, to establish the connection between the causes of death and the alleged negligence of the petitioners. Thus, the Supreme Court affirmed the decision of the Court of Appeals, holding Reyno and De Vera jointly and severally liable for damages based on the doctrine of res ipsa loquitur.