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NOGALES v. CAPITOL MEDICAL CENTER

FACTS:

Corazon Nogales, under the prenatal care of Dr. Oscar Estrada, was admitted to Capitol Medical Center (CMC) for her fourth pregnancy. Dr. Estrada noted her high blood pressure and leg edema indicating preeclampsia. While in labor, Corazon experienced convulsions and started bleeding profusely. Despite efforts to resuscitate her, Corazon died due to postpartum hemorrhage. A complaint for damages was filed against CMC and Dr. Estrada, alleging negligence in Corazon's treatment. The trial court declared Dr. Estrada solely liable for damages.

The court found no legal basis to hold other defendants civilly liable. Dra. Ely Villaflor was following orders from Dr. Estrada and did not have the correct diagnosis. Nurse Dumlao acted based on presumed orders from Dr. Estrada. Dra. Rosa Uy had no knowledge of the alleged mismanagement. Dr. Enriquez, as an anesthesiologist, had no control over Dr. Estrada and Dra. Villaflor. Dr. Lacson had no responsibility for any delay in providing blood. Dr. Espinola's treatment was based on information given over the phone. CMC, as a hospital, had no control over attending physicians who were not its employees.

The trial court ruled in favor of the petitioners, holding Dr. Estrada solely liable for the patient's death. The Court of Appeals affirmed this decision and rejected the argument that CMC should be held liable. The Court of Appeals held that CMC cannot be responsible for the negligence of an independent contractor physician. Petitioners appealed to the Supreme Court, focusing solely on CMC's liability. The Supreme Court affirmed Dr. Estrada's liability but emphasized that CMC should also be held liable for the negligence of its other healthcare professionals. The Court recognized that determining liability and the extent of each respondent's liability were necessary to resolve the case.

The petitioner initially believed that Dr. Estrada was a salaried employee of CMC. However, it was later discovered that he was not directly employed by the hospital. The petitioner argued that CMC should still be responsible for Dr. Estrada's actions since they allowed him to practice and admit patients at the hospital.

ISSUES:

  1. Is Capitol Medical Center (CMC) vicariously liable for the negligence of Dr. Oscar Estrada?

  2. What is the extent of liability of the other respondents (Dr. Ely Villaflor, Dr. Rosa Uy, Dr. Joel Enriquez, Dr. Perpetua Lacson, Dr. Noe Espinola, and Nurse J. Dumlao)?

RULING:

  1. On Capitol Medical Center's (CMC) Liability

    • CMC is held vicariously liable for the negligence of Dr. Oscar Estrada on the doctrine of apparent authority. CMC's actions created a reasonable belief in the Spouses Nogales that Dr. Estrada was an agent or employee of CMC. This liability extends to the amounts awarded as damages, with each award earning legal interest at the rate of six percent (6%) per annum computed from the date of the judgment of the trial court.

  2. On the Liability of Other Respondents

    • Dr. Ely Villaflor Not liable as she was merely following Dr. Estrada's instructions and informed him of necessary details.

    • Dr. Rosa Uy Not liable as she was only responsible for taking the clinical history and physical examination and did not participate in the delivery.

    • Dr. Joel Enriquez Not liable as his expertise did not cover obstetrics and gynecology and there was no evidence he observed errors and failed to correct them.

    • Dr. Perpetua Lacson Not liable due to the reasonable handling of the blood request and no evidence of negligence.

    • Dr. Noe Espinola Not liable as his recommendation for hysterectomy was based on credible information, and he was not present during the initial management of Corazon's case.

    • Nurse J. Dumlao Not liable due to the absence of evidence proving that the alleged wrongful administration of hemacel proximately caused Corazon's death.

PRINCIPLES:

  1. Doctrine of Apparent Authority A hospital can be held liable for the negligent acts of an independent contractor-physician if the hospital's actions lead a reasonable person to believe that the doctor was an agent or employee of the hospital.

  2. Respondeat Superior and Borrowed Servant Doctrine These doctrines attribute liability to the employer for the acts of its employees or temporary servants under the control of a superior.

  3. Control Test Used to determine if an employer-employee relationship exists by assessing the employer's control over the job performance of the worker.

  4. Adhesion Contracts Contracts presented on a "take it or leave it" basis, typically found against the party offering such contracts when disputes arise.

  5. Award of Interest on Damages Permissible under Article 2211 of the Civil Code in cases of crimes and quasi-delicts.