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DR. MILAGROS L. CANTRE v. SPS. JOHN DAVID Z. GO

FACTS:

Respondent spouses John David Z. Go and Nora S. Go filed a complaint for damages against petitioner Dr. Milagros L. Cantre, Dr. Rainerio S. Abad, and the hospital. The case revolves around Nora's admission to the hospital with Dr. Cantre as her attending physician. After giving birth, Nora experienced excessive bleeding and a drop in blood pressure. Dr. Cantre and the resident physician conducted medical procedures to address these issues. While recovering, Nora's husband noticed a fresh wound on her left arm, suspected to be a burn from a droplight. An investigation confirmed this suspicion. Despite undergoing skin grafting and scar revision surgeries, Nora's arm still exhibited a visible mark and limited movement. The trial court ruled in favor of the plaintiffs and awarded damages. The Court of Appeals affirmed the trial court's decision with modification. Petitioner filed a motion for reconsideration, which was subsequently denied. Consequently, petitioner filed a petition for review on certiorari before the Supreme Court, raising various assigned errors and issues.

ISSUES:

  1. Are the questioned additional exhibits admissible in evidence?

  2. Is petitioner liable for the injury suffered by respondent Nora Go?

RULING:

  1. The additional exhibits are admissible in evidence.

  2. Petitioner is liable for the injury suffered by respondent Nora Go.

PRINCIPLES:

  1. Res Ipsa Loquitur Doctrine: The existence of an injury can justify a presumption of negligence when the injury:

    • Ordinarily does not occur in the absence of negligence.

    • Is caused by an instrumentality within the exclusive control of the defendant.

    • Is not due to any conduct by the plaintiff.

  2. Captain of the Ship Doctrine: A surgeon in charge of an operation is liable for the negligence of assistants under the surgeon’s control during an operation.

  3. Negligence: Intent is immaterial in negligence cases; where negligence exists and is proven, it automatically gives the injured a right to reparation for the damage caused.

  4. Civil Code Provisions on Damages:

    • Article 2176: Fault or negligence causing damage obliges the injurer to pay for the damage done.

    • Article 2217: Moral damages include physical suffering, mental anguish, and other similar injuries, which may be recovered if they are the proximate result of the defendant's wrongful act or omission.