Batiquin v. CA

G.R. No. 118231 (July 5, 1996)

Facts:

Dr. Victoria L. Batiquin was a Resident Physician at the Negros Oriental Provincial Hospital from January 9, 1978, to September 1989, and served as the Acting Head of the Department of Obstetrics and Gynecology during part of that time. Flotilde G. Villegas, a married woman, sought prenatal care from Dr. Batiquin and underwent a cesarean section on September 21, 1988, assisted by Dr. Doris Teresita Sy and other medical staff. After the surgery, Villegas was discharged on September 28, 1988, and paid Dr. Batiquin a professional fee of P1,500.

Post-surgery, Villegas experienced abdominal pain, fever, and loss of appetite, leading her to consult Dr. Batiquin multiple times. Despite treatment, her condition worsened, prompting her to seek help from Dr. Ma. Salud Kho at Holy Child's Hospital on January 20, 1989. Dr. Kho discovered an abdominal mass and signs of infection, which necessitated a second surgery. During this operation, Dr. Kho found two ovarian cysts and a piece of rubber material, described as a "foreign body," which was believed to be a remnant from the previous surgery.

The piece of rubber was not presented in court, and while Dr. Kho testified about its existence, the trial court deemed her evidence as hearsay due to the lack of direct testimony from those who prepared the related medical documents. The trial court ruled in favor of Dr. Batiquin, concluding that the evidence did not sufficiently establish negligence.

The Court of Appeals, however, reversed this decision, finding that Dr. Kho's testimony sufficiently established that the rubber left in Villegas' abdomen was the cause of her subsequent medical issues. The appellate court held that Dr. Batiquin was negligent for failing to remove the foreign body during the initial surgery and awarded damages to Villegas.

Legal Issues:

1. Whether the Court of Appeals erred in reversing the trial court's decision based on the evidence presented.
2. Whether Dr. Batiquin was negligent in her surgical duties, leading to the injury of Mrs. Villegas.
3. The applicability of the doctrine of res ipsa loquitur in establishing negligence.

Arguments:

• Petitioners' Arguments (Dr. Batiquin):

  • The trial court's findings were based on credible evidence, and the Court of Appeals misapprehended the facts.
  • Dr. Kho's testimony was based on hearsay and lacked corroboration, particularly regarding the piece of rubber.
  • The trial court's decision should stand as it was supported by the evidence presented.

• Respondents' Arguments (Spouses Villegas):

  • The Court of Appeals correctly found that Dr. Kho's testimony established the presence of the rubber and the negligence of Dr. Batiquin.
  • The evidence of the foreign body and its consequences on Villegas' health warranted a finding of negligence.
  • The damages awarded were justified given the suffering and medical expenses incurred.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decision of the Court of Appeals, agreeing that the evidence presented by Dr. Kho was credible and established that a piece of rubber was left inside Villegas' abdomen. The Court emphasized the application of the doctrine of res ipsa loquitur, which allows for an inference of negligence when an injury occurs under circumstances that typically do not happen without negligence.

The Court noted that:

• The cesarean section was under the exclusive control of Dr. Batiquin, and the presence of the rubber indicated a failure to exercise proper care.
• The absence of direct evidence regarding the exact cause of the foreign body did not negate the presumption of negligence.
• The Court recognized the importance of the medical profession's duty to uphold high standards of care, and Dr. Batiquin's actions fell short of these standards.

Significant Legal Principles Established:

1. Doctrine of Res Ipsa Loquitur: This principle allows for the inference of negligence when the injury-causing instrumentality is under the control of the defendant, and the injury is of a kind that does not occur in the absence of negligence.
2. Credibility of Witnesses: The Court emphasized that positive testimony is generally stronger than negative testimony, and the credibility of witnesses plays a crucial role in establishing facts in negligence cases.
3. Standard of Care in Medical Practice: The ruling reinforced the expectation that medical professionals must adhere to a high standard of care, and failure to do so can result in liability for negligence.