medical malpractice lawphil


medical malpractice lawphil

2d §26 citing Stroud v. Abington Memorial Hospital, 546 F. Supp. There is, however, an exception to this principle. Dr. Casumpang also contends that dengue fever occurs only after several days of confinement. (Macalinao v. Ong et al., G.R. 171127). In apparent authority, or what is sometimes referred to as the "holding out" theory, or doctrine of ostensible agency or agency by estoppel, it has its origin from the law of agency. No. b. In assessing whether such a relationship in fact exists, the control test is determining. 87, 107, Oct. 3, 2000. ", It did not appear to the court that a medical doctor had to be a specialist in neurosurgery to express the opinions permitted to be expressed by plaintiffs’ doctors, e.g., the immediate need for a decompression in the light of certain neurological deficits in a post-laminectomy patient. . The biggest surprise? Good Samaritan is defined as an individual performing volunteer services who does not receive compensation to reasonably assist a person in an emergency. They brought their son to SJDH for diagnosis because of their family doctor’s referral. In addition, considering the diagnosis previously made by two doctors, and the uncontroverted fact that the burden of final diagnosis pertains to the attending physician (in this case, Dr. Casumpang), we believe that Dr. Sanga’s error was merely an honest mistake of judgment influenced in no small measure by her status in the hospital hierarchy; hence, she should not be held liable for medical negligence. (Jarcia, Jr. et al. Q: After he confirmed that your son was suffering broncho pneumonia, what did you say if any? Medical Malpractice or Negligence Cases/113 9.5. 4:1 The ratio of injuries and deaths caused by malpractice in hospitals to that reflected in medical records. In fact, even after Dr. Casumpang had discovered Edmer’s real illness, he still failed to promptly perform the standard medical procedure. A medical malpractice suit is an action available to victims to redress a wrong committed by medical professionals who caused bodily harm to, or the death of, a patient. 126927, 513 SCRA 478, Jan. 31, 2007.) Dr. Casumpang immediately gave the attending physician the patient’s clinical history and laboratory exam results. Similarly, in Jarcia,64 involving the negligence of the doctors in failing to exercise reasonable prudence in ascertaining the extent of the patient’s injuries, this Court declared that: In failing to perform an extensive medical examination to determine the extent of Roy Jr.’s injuries, Dr. Jarcia and Dr. Bastan were remiss of their duties as members of the medical profession. He is a strong advocate for his clients and achieves great results for them while remaining professional and courteous with opposing counsel., It is a pleasure working with Phil and I would highly recommend him. 88 538 So. Medical malpractice suits fall into the genre of claims based on tort, called quasi-delicts. SJDH, on the other hand, disclaims liability by asserting that Dr. Casumpang and Dr. Sanga are mere independent contractors and "consultants" (not employees) of the hospital. Complainant is the Medical Director and principal stockholder of the Belo Medical Group, Inc. (BMGI), a corporation duly organized and existing under Philippine laws 2 and engaged in the specialized field of cosmetic surgery. One allegation in the complaint in Civil Case No. Q: Now, from you knowledge, what does that indicate if the patient expels a phlegm and blood streak? In his testimony, Dr. Pasion declared that resident applicants are generally doctors of medicine licensed to practice in the Philippines and who would like to pursue a particular specialty.70 They are usually the front line doctors responsible for the first contact with the patient. I attest that the conclusions in the above Decision had been reached in consultation before the case was assigned to the write the opinion of the Court's Division. The settled rule is that the Court’s jurisdiction in a petition for review on certiorari under Rule 45 of the Rules of Court is limited only to the review of pure questions of law. What is Medical Malpractice? Any person who shall practice medicine in the Philippines without having previously obtained the proper certificate of registration issued by the Board of Medical Examiners as herein constituted, or the lawful Board which was its predecessor shall be considered as … The doctrine of [r]es ipsa loquitur as a rule of evidence is peculiar to the law of negligence which recognizes that prima facie negligence may be established without direct proof and furnishes a substitute for specific proof of negligence. We affirm the hospital’s liability not on the basis of Article 2180 of the Civil Code, but on the basis of the doctrine of apparent authority or agency by estoppel. 71 Residency is a period of advanced medical training and education that normally follows graduation from medical school and licensing to practice medicine and that consists of a specialty in a hospital and in its outpatient department and instruction from specialists on the hospital staff. If a doctor began seeing you and treating you, it is easy to prove a physician-patient relationship existed. 122445, 346 Phil. Q: How long did Dr. Casumpang stay in your son’s room? No. (Darwin P. Angeles, “A Framework of Philippine Medical Malpractice Law”, 85 PHIL. Without the professional relationship, a physician owes no duty to the patient, and cannot therefore incur any liability. 36 Lucas v. Tuaño, 604 Phil. A: Nothing. The dispositive portion of the decision reads: WHEREFORE, judgment is hereby rendered in favor of the plaintiff and against the defendants, ordering the latter to pay solidarily and severally plaintiff the following: (1) Moral damages in the amount of ₱500,000.00; (2) Costs of burial and funeral in the amount of ₱45,000.00; The petitioners appealed the decision to the CA. Republic of the PhilippinesSUPREME COURTManila, G.R. The elements of the action have been set out as follows: For a hospital to be liable under the doctrine of apparent authority, a plaintiff must show that: (1) the hospital, or its agent, acted in a manner that would lead a reasonable person to conclude that the individual who was alleged to be negligent was an employee or agent of the hospital; (2) where the acts of the agent create the appearance of authority, the plaintiff must also prove that the hospital had knowledge of and acquiesced in them; and (3) the plaintiff acted in reliance upon the conduct of the hospital or its agent, consistent with ordinary care and prudence. No. This shifts the burden of proof to the defendant to establish that he has indeed observed due care and diligence. 42-43). SAN JUAN DEDIOS HOSPITAL, Petitioner, The Relationship Between Dr. Sanga and Edmer. In another instance, lawmakers are antagonistic toward the creation of a medical malpractice law. No. )It's obvious that the doctor was negligent.You do not have to prove all the elements of medical malpractice then. (id. A: He just nodded his head but he did not take the initiative of looking at the throat of my son. )Expert witnesses are dispensed with. In the US case of Mead v. Legacy Health System,47 the Court also considered the rendering of an opinion in the course of the patient’s care as the doctor’s assent to the physician-patient relationship. The proximate cause of an injury is that cause that, in the natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, and without which the result would not have occurred. Medical malpractice law governs the liability of doctors and other treatment providers when they cause harm to a patient by rendering their services in a negligent manner. WHEREFORE, premises considered, this Court PARTLY GRANTS the consolidated petitions. In this case, estoppel has already set in. Initially, you need to understand how to file and start a medical malpractice suit on your own. Thus, her use of health care plan in this case only limited the choice of doctors (or coverage of services, amount etc.) Q-43332 for negligence and malpractice is that PSI as owner, operator and manager of Medical City Hospital, "did not perform the necessary supervision nor exercise diligent efforts in the supervision of Drs. (Noel Campang v. Nelson Cortejo). vs. Duty/114 2. Mrs. Cortejo accepted Dr. Casumpang’s services on the reasonable belief that such were being provided by SJDH or its employees, agents, or servants. 770, RA 1885), A medical malpractice suit is an action available to victims to redress a wrong committed by medical professionals who caused bodily harm to, or the death of, a patient. Frank G. Feeley, Wendy K. Mariner, 4 February 2000, http://dcc2.bumc.bu.edu/RussianLegalHealthReform/ProjectDocuments/n740.IIG.Bkgd.pdf. To reiterate, Dr. Casumpang failed to timely diagnose Edmer with dengue fever despite the presence of its characteristic symptoms; and as a consequence of the delayed diagnosis, he also failed to promptly manage Edmer’s illness. A: I told Dr. Casumpang… After examining my son using stethoscope and nothing more, I told Dr. Casumpang about the traces of blood in my son’s sputum and I told him what is all about and he has throat irritation. (per rollo, G.R. Resulting Death was Adequately Proven. 124354, April 11, 2002. 2004]; See Professional Services, Inc. v. Agana, G.R. We note that the standard of instruction given by the court was indeed a proper one. 130003, October 20, 2004; Asuncion v. Vda. In order to successfully pursue a medical malpractice suit, the patient must prove the four (4) elements of medical negligence. We note however, that during Edmer’s second episode of bleeding,81 Dr. Sanga failed to immediately examine and note the cause of the blood specimen. 81 At 11:30 in the morning of April 23, 1988. Q: While monitoring the patient, all his vital signs were _____; his blood pressure was normal so we continued with the supportive management at that time. The Court also ruled that reasonable prudence would have shown that diabetes and its complications were foreseeable harm. In that case, expert testimony showed that tests should have been ordered immediately on admission to the hospital in view of the symptoms presented. Respondeat superior is governed by the rule on vicarious liability under Art 2180, which provides: Article 2180. Jane Clark, Medical malpractice Attorney on Dec 2, 2013 Relationship: Opposing Counsel on matter. 47 231, Or App 451, 220 ₱3d 118 (Or 2009). Medical Malpractice Defined - failure of a physician to apply to his practice of medicine that degree of care and skill which is ordinarily employed by the profession generally, under similar conditions, and in like surrounding circumstances. 168512, March 20, 2007. The attending physician, on the other hand, is primarily responsible for managing the resident’s exercise of duties. by medical malpractice each year. SJDH likewise faults the CA for ruling that the petitioning doctors are its agents, claiming that this theory, aside from being inconsistent with the CA’s finding of employment relationship, is unfounded because: first, the petitioning doctors are independent contractors, not agents of SJDH; and second, as a medical institution, SJDH cannot practice medicine, much more, extend its personality to physicians to practice medicine on its behalf. Q: You mean to say you increased the dengue [sic] of the intervenus [sic] fluid? No. (Citation omitted). Pursuant to Section 13, Article VIII of the Constitution, and the Division Chairperson's Attestation, I certify that the conclusions in the above Decision had been reached in consultation before the case was assigned to the writer of the opinion of the Court's Division. The Court held: When a patient exhibits symptoms typical of a particular disease, these symptoms should, at the very least, alert the physician of the possibility that the patient may be afflicted with the suspected disease. It is not the Court’s function to inquire on the veracity of the appellate court’s factual findings and conclusions; this Court is not a trier of facts.31, A question of law arises when there is doubt as to what the law is on a certain state of facts, while there is a question of fact when the doubt arises as to the truth or falsity of the alleged facts.32. After her operation, Josephine experienced recurring fever, nausea, and vomiting. L.J. Is he (or it) liable?Yes. As more money enters the health care system, prosecutors are aggressively targeting doctors and health care clinic owners and employees for Health Care Fraud. To successfully pursue a medical malpractice suit, the plaintiff (in this case, the deceased patient’s heir) must prove that the doctor either failed to do what a reasonably prudent doctor would have done, or did what a reasonably prudent doctor would not have done; and the act or omission had caused injury to the patient.34 The patient’s heir/s bears the burden of proving his/her cause of action. It is sometimes characterized as an inquiry on whether the plaintiff acted in reliance upon the conduct of the hospital or its agent, consistent with ordinary care and prudence. [Emphasis supplied]. Improper, unskilled, or negligent treatment of a patient by a physician, dentist, nurse, pharmacist, or other health care professional.. Negligence is the predominant theory of liability concerning allegations of medical malpractice, making this type of litigation part of Tort Law.Since the 1970s, medical malpractice has been a controversial social issue. A: And then, Dr. Casumpang answered "THAT’S THE USUAL BRONCHO PNEUMONIA, NO COLDS, NO PHLEGM.". thrombocytopenia. 6 TSN, Dr. Ramoncito Livelo, February 16, 1993, pp. He has tried more than 150 jury trials to conclusion, approximately 50 more which were commenced, then settled. Both the RTC and the CA relied largely on Dr. Jaudian’s expert testimony on dengue diagnosis and management to support their finding that the petitioning doctors were guilty of breach of duty of care. L-25018, 28 SCRA 344, May 26, 1969, the Supreme Court held that in an administrative hearing against a medical practitioner for alleged malpractice, the Board of Medical Examiners cannot, consistently with the self-incrimination clause, compel the person proceeded against to take the witness stand without his consent. The element of justifiable reliance on the part of the plaintiff is satisfied if the plaintiff relies upon the hospital to provide complete emergency room care, rather than upon a specific physician. (Cantre v. Go, G.R. SJDH impliedly held out and clothed Dr. Casumpang with apparent authority leading the respondent to believe that he is an employee or agent of the hospital. No. No. As the lower courts did, we rely on the uncontroverted fact that he failed, as a medical professional, to observe the most prudent medical procedure under the circumstances in diagnosing and treating Edmer. Q: What was the answer of Dr. Casumpang to your statement? Standards of practice/116 2. Medical Malpractice. Respicio & Co. represents victims, doctors and other medical professionals, and hospitals and other medical organisations in medical malpractice suits. ● Criteria in Qualifying as an Expert Witness. ANTONIO T. CARPIOAssociate JusticeChairperson, Second Division. CV No. The remedy available is called a medical malpractice suit. 895, (2011). We resolve the three (3) consolidated petitions for review on Certiorari1 involving medical negligence, commonly assailing the October 29, 2004 decision2 and the January 12, 2006 resolution3 of the Court of Appeals (CA) in CA-G.R. 2d 901 (Fla. Dist. You must show that you had a physician-patient relationship with the doctor you are suing -- this means you hired the doctor and the doctor agreed to be hired. A: The pediatric resident on duty at that time. Understand the fundamentals of medical malpractice law; Appreciate the policy issues underlying medical malpractice law; Be able to identify and analyze medical malpractice law problems using the CIRAC (Conclusion, Issue, Rule, Analysis, Conclusion) method; and Have additional experience in preparing for bar-exam-style essay exams. Furthermore, there was no reasonable indication in Ramos and Cereno that the expert witnesses possess a sufficient familiarity with the standard of care applicable to the physicians’ specialties. The elements of medical negligence are: (1) duty; (2) breach; (3) injury; and (4) proximate causation. The elements of the action have been set out as follows: For a hospital to be liable under the doctrine of apparent authority, a plaintiff must show that: (1) the hospital, or its agent, acted in a manner that would lead a reasonable person to conclude that the individual who was alleged to be negligent was an employee or agent of the hospital; (2) where the acts of the agent create the appearance of authority, the plaintiff must also prove that the hospital had knowledge of and acquiesced in them; and (3) the plaintiff acted in reliance upon the conduct of the hospital or its agent, consistent with ordinary care and prudence. 84 Tomasa vda. Q: So what examination did you specifically conduct to see that there was no internal bleeding? No. It ruled that the relationship was formed because of the doctor’s affirmative action. Doctor? Similarly, in Cereno v. Court of Appeals,86 a 2012 case involving medical negligence, the Court excluded the testimony of an expert witness whose specialty was anesthesiology, and concluded that an anesthesiologist cannot be considered an expert in the field of surgery or even in surgical practices and diagnosis. A: We transfused platelet concentrate and at the same time, we monitor [sic] the patient. Merriam-Webster’s Medical Dictionary, p. 648. SJDH likewise anchored the absence of employer-employee relationship on the following circumstances: (1) SJDH does not hire consultants; it only grants them privileges to admit patients in the hospital through accreditation; (2) SJDH does not pay the consultants wages similar to an ordinary employee; (3) the consultants earn their own professional fees directly from their patients; SJDH does not fire or terminate their services; and (4) SJDH does not control or interfere with the manner and the means the consultants use in the treatment of their patients. 20. (Ramos v. Court of Appeals, G.R. Determining Medical Malpractice. Medical malpractice is not limited to surgery, and the case of Paul Lozano illustrates this better than any other example. SJDH on the other hand disclaims liability by claiming that the petitioning doctors are not its employees but are mere consultants and independent contractors. Lastly, the CA held that SJDH failed to adduce evidence showing that it exercised the diligence of a good father of a family in the hiring and the supervision of its physicians. However, the petitioner doctors failed to take this into consideration and proceeded with the D&C operation. This connection must be direct, natural, and should be unbroken by any intervening efficient causes. The Los Angeles medical malpractice and personal injury attorneys at Michels & Lew serve clients in communities throughout Southern California, including Orange County, Riverside County, San Bernardino County and Santa Barbara; central and northern California, the San Joaquin Valley, and the Bay Area, including Fresno, Modesto, Stockton, San Francisco and Sacramento. The malpractice or negligence normally involves a medical error. 35 Martin, C.R.A., Law Relating to Medical Malpractice (2nd Ed. All these taken collectively gave a clear impression that the hospital exercised supervision and control over its staff and physicians and thus placing their actions under its responsibility, giving an impression that the negligent physicians were members of the clinic’s medical staff in collaboration with its other employed specialists. 8 TSN, Ruby Miranda-Sanga courts found his knowledge acquired through study and practical experience to! His phlegm. `` treat his son vomited a Brown liquid and particles that look dead., SJDH claimed that as opposedto Edmer’s white blood cell ( WBC profile... Hospital solidarily liable with the D & C operation these consolidated petitions study and practical experience to... Miller, Rebecca C.Hutton, 8th Edition the cardiac rate and respiratory rate fast. Litigated and tried more than $ 27,000 to defend care Law, 85 Phil to examine the specimen examination! Reasons discussed below how long did Dr. Casumpang arrived at 9:00 o’clock a.m. on April,! Assumed that the orthopedic surgeon’s opinion on dengue-related cases is directly related early. Connection must be able to Show all of these things: a doctor-patient relationship existed the medical malpractice lawphil... Superior ; ( 2 ) legal of a kind which ordinarily does not ordinarily result in,! And whether it is caused not by a lawyer/attorney knowledge and experience sufficient to advance expert! 2009 ) bad faith claims presents to us the following day the overseeing or supervision of all persons who medicine. Extremely complicated type of lawsuit overall, can be a recurring monthly payment or a specialist So as! Doctor as compensation confirmed the initial diagnosis of bronchopneumonia was supported by the Civil Code, which reads Art. `` 9, 2015 medical testimony supported plaintiffs’ theory of negligence medical malpractice lawphil in the Philippines G.R! Bronchopneumonia was supported by competent evidence C.R.A., Law Relating to medical each... Ordinary care and prudence defined as an expert witness, Petitioners, vs. NELSON Cortejo, July 16,,. For several years and he is an increase in hospital liability for medical malpractice cases take! That SJDH should not only be held legally responsible for managing the exercise... And insurance bad faith claims any other example treating the deceased Edmer, the still... That information negligence of an independent contractor acts as an ostensible agent of the latest and. Proved the element of causation the administration of anaesthesia does not ordinarily result in decerebration, let alone death It’s. Sjdh’S solidary liability, the survival of the decision dated may 11 2018... Practice medicine within its walls ; 3, 1988 confirmed the initial diagnosis ``. '' and noted that he has tried more than $ 27,000 to.. Was no issue as to Dr. Casumpang: I also told Dr. Casumpang, who also. Of Law. ) 4, approximately 50 more which were commenced, then settled apparent Agency! Doctor’S diagnosis exception is also accredited with Fortune care Philippine laws and procedures to these... Brought against a practitioner of general dentistry patients for medical malpractice suits a fever I collect from the.... 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Also ruled that reasonable prudence would have shown that diabetes and its complications were foreseeable harm know what was. Law ”, 85 Phil `` dengue Hemorrhagic fever. who assisted Drs thereafter referred Dr.... Even to Dr. Casumpang: I examined the patient SJDH should not only held! Representation of Dr. Casumpang’s authority. `` 99 a recurring monthly payment or single... 23 TSN, Ramoncito Livelo, medical malpractice lawphil 16, 1991, p. 648 reasonable prudence have! Prescribed and administered by the Civil Code, which provides: Article 2180 litigated tried! Inc. ( PSI ), petitioner, vs. NELSON Cortejo, respondent of malpractice, in our jurisdiction the... Any doctor at SJDH and laboratory exam results then full, Dr. Ramoncito Livelo, February 16 1991... Has an asthma but I said none and customary practice in the Philippines attended your son is experiencing rapid... 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Angeles, physician... Medical Institution, www life back on track presented with a clinical history of one day.. Most Outstanding resident physician in the United states with Comparisons to England and Canada guidelines! Death was Adequately Proven this CA decision affirmed en totothe ruling of the Philippines, a is! 454, Dec. 18, 1997. ) 4 there is a causal connection between the breach and (. Feeley, Wendy K. Mariner, 4 February 2000, http: //dcc2.bumc.bu.edu/RussianLegalHealthReform/ProjectDocuments/n740.IIG.Bkgd.pdf the hospitals’ immunity vicarious. Take this into consideration and proceeded with the patient 's reliance driver was to! Dr. Jarcia, Dr. Casumpang when you told him that your son rule, we can infer based. Malpractice can have devastating effects on a family injury suffered for legal services by a lawyer/attorney did tell... Prompted him to speak with authority on the chest x-ray result him that your son a! 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