Atienza v. Board of Medicine
G.R. No. 177407 (February 9, 2011)
Facts:
The case revolves around a medical malpractice complaint filed by Editha Sioson against several doctors, including petitioner Rico Rommel Atienza, for alleged gross negligence during a kidney operation. Editha initially sought medical attention for lumbar pains at Rizal Medical Center (RMC) in February 1995. In 1999, she was referred to Dr. Pedro Lantin III, who ordered diagnostic tests that revealed her left kidney was non-functioning and non-visualizing, while her right kidney was normal. Despite this, during a surgical procedure in September 1999, Editha's functioning right kidney was removed instead of the left.
On February 18, 2000, Editha's husband, Romeo Sioson, filed a complaint with the Board of Medicine (BOM) against the involved doctors, alleging gross negligence. The complaint included a formal offer of documentary evidence by Editha, which consisted of several X-ray request forms intended to prove that both kidneys were in their proper anatomical locations at the time of the operation. Petitioner Atienza objected to the admission of these exhibits, arguing they were inadmissible due to being mere photocopies, lacking proper identification and authentication, and being hearsay.
The BOM admitted Editha's exhibits in its Order dated May 26, 2004, prompting Atienza to file a petition for certiorari with the Court of Appeals (CA) to challenge this decision. The CA dismissed the petition, leading to Atienza's appeal.
Legal Issues:
Procedural Issue: Whether petitioner Atienza availed of the proper remedy in filing a petition for certiorari under Rule 65 of the Rules of Court to challenge the BOM's orders admitting Editha's evidence.
Substantive Issue: Whether the CA erred in upholding the BOM's admission of what Atienza claimed were incompetent and inadmissible exhibits, potentially affecting his professional license.
Arguments:
Petitioner Atienza's Arguments:
- The exhibits were inadmissible as they violated the best evidence rule, were not properly identified or authenticated, constituted hearsay, and were incompetent to prove their intended purpose.
- The admission of these exhibits could lead to a deprivation of his professional license, which is a property right.
Respondent Editha Sioson's Arguments:
- The rules of evidence are not strictly applied in administrative proceedings, and the BOM acted within its jurisdiction in admitting the evidence.
- The exhibits were relevant to the case, and their admission did not prejudice Atienza's substantive rights.
Court's Decision and Legal Reasoning:
The Supreme Court affirmed the CA's decision, finding no grave abuse of discretion by the BOM in admitting Editha's exhibits. The Court noted that:
Proper Remedy: Atienza correctly filed a petition for certiorari as the BOM's orders were interlocutory and not subject to appeal until a final judgment was rendered.
Admissibility of Evidence: The Court emphasized that the strict rules of evidence do not apply in administrative proceedings. The BOM was justified in admitting the exhibits to assess their probative value later. The Court highlighted that the best evidence rule was not applicable since the inquiry was not about the contents of the documents but rather the anatomical locations of Editha's kidneys, which could be established through other means.
Judicial Notice: The Court took judicial notice that human kidneys are typically in their proper anatomical locations, thus the fact that Editha's kidneys were in their correct positions at the time of surgery did not need to be proven through the exhibits.
Hearsay and Authentication: The Court found that the exhibits did not constitute hearsay as they were relevant to the case, and the inability to produce original documents due to the hospital's relocation justified the admission of photocopies.
Significant Legal Principles Established:
- The rules of evidence are applied more liberally in administrative proceedings compared to judicial proceedings.
- The distinction between the admissibility of evidence and its probative value is crucial; evidence may be admitted even if its relevance is questionable, allowing for later assessment of its weight.
- Judicial notice can be invoked for facts that are universally acknowledged, such as the anatomical positions of human organs.