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PROFESSIONAL SERVICES v. CA

FACTS:

The case involves a medical malpractice claim filed by the Aganas against the Philippine Society of Anesthesiologists, Inc. (PSI), Dr. Ampil, and Dr. Fuentes. The Aganas allege that Dr. Ampil, who performed anesthesia during the childbirth of Mrs. Agana, was negligent and caused her temporary paralysis.

PSI, together with two doctors, was sued for negligence by the respondents. The Regional Trial Court (RTC) held PSI, along with one doctor, solidarily liable for damages. The Court of Appeals (CA) absolved one doctor but affirmed the liability of PSI. The Supreme Court affirmed the CA decision, holding PSI directly liable based on the existence of an employer-employee relationship between PSI and the doctors, as well as PSI's accreditation of the doctor and apparent authority doctrine. PSI filed a motion for reconsideration, which was denied.

PSI now seeks reconsideration of the Court's rulings, arguing that there is no employer-employee relationship between PSI and the doctor, the respondents did not primarily rely on the hospital's apparent authority, and PSI cannot be held liable under the doctrine of corporate negligence.

The trial court found that there was no employer-employee relationship between PSI and Dr. Ampil, who was considered a consultant and independent contractor. The Aganas did not question this finding. The court also found Dr. Ampil and Dr. Fuentes liable for negligence.

On appeal, the Court of Appeals mistakenly referred to PSI and Dr. Ampil as having an employer-employee relationship but viewed their relationship as one of apparent agency.

The Supreme Court, after considering the arguments raised, held that PSI was liable to the Aganas. It found that PSI was not liable under the principle of respondeat superior as there was no evidence of an employment relationship with Dr. Ampil. Instead, PSI was held liable under the principle of ostensible agency for the negligence of Dr. Ampil and under the principle of corporate negligence for its failure to perform its duties as a hospital.

The Court explained that within the hospital setting, three legal relationships exist: (1) between the hospital and the doctor; (2) between the hospital and the patient; and (3) between the patient and the doctor. The nature of each relationship determines the extent of the hospital's liability for the doctor's negligence.

The Court applied the control test to determine the existence of an employer-employee relationship between the hospital and the doctor. It noted that the hospital controlled the means and details of the process by which the doctor accomplished his tasks. The hospital had specific work-schedules for the doctors and monitored their work through nursing supervisors and orderlies. Even though the Aganas did not question the finding of no employment relationship between PSI and Dr. Ampil, the Court still discussed and affirmed the finding to allay concerns.

ISSUES:

  1. Can PSI be held liable for the negligence of Dr. Miguel Ampil in leaving surgical gauzes in Natividad Agana's body, given that no employer-employee relationship exists between PSI and Dr. Ampil?

  2. Can PSI be held accountable under the doctrine of corporate negligence for not addressing the negligence committed by Dr. Ampil within its hospital premises?

RULING:

  1. Liability for Negligence of Dr. Miguel Ampil

    The Court held that PSI could not be held liable under the principle of respondeat superior (vicarious liability) for lack of an employer-employee relationship with Dr. Ampil. However, PSI is liable under the principle of ostensible agency because it created the impression that Dr. Ampil was its agent, which influenced the Aganas' decision to seek his services.

  2. Corporate Negligence

    The Court found PSI directly liable under the concept of corporate negligence due to its failure to conduct an internal investigation upon learning about the missing surgical gauzes and not taking active steps to rectify the negligence committed within its premises. This derelict action fell below its own defined standards of hospital care.

PRINCIPLES:

  1. Ostensible Agency: A hospital can be held liable for the negligence of doctors practicing within its premises if it created an impression to the patient that these doctors were agents or employees of the hospital.

  2. Corporate Negligence: A hospital has a duty to exercise reasonable care to ensure the safety of its patients, including taking active steps to rectify any negligence occurring within its premises. This duty is independent of the relationship between the hospital and the consulting physician.

  3. Control Test: The existence of an employer-employee relationship for purposes of vicarious liability is determined by whether the hospital controls both the means and details of the work performed by the doctor.

  4. Self-Defined Standards: A hospital's duties and care standards, once publicly defined or judicially admitted, set a benchmark for evaluating its negligence in patient care.

  5. Pro Hac Vice (For This Occasion Only): The Court emphasized that its ruling on PSI's liability is specific to the unique facts of this case and should not be construed as setting a precedent for holding hospitals liable under similar circumstances in other cases.