G.R. No. 158996 November 14, 2008
SPOUSES FREDELICTO FLORES (deceased) and FELICISIMA FLORES, petitioners, vs. SPOUSES DOMINADOR PINEDA and VIRGINIA SACLOLO, and FLORENCIO, CANDIDA, MARTA, GODOFREDO, BALTAZAR and LUCENA, all surnamed PINEDA, as heirs of the deceased TERESITA S. PINEDA, and UNITED DOCTORS MEDICAL CENTER, INC., respondents.

FACTS

Teresita Pineda, a 51-year-old woman, consulted Dr. Fredelicto Flores on April 17, 1987, complaining of general body weakness, loss of appetite, frequent urination and thirst, and on-and-off vaginal bleeding. Dr. Fredelicto suspected diabetes and advised a follow-up or a check-up at United Doctors Medical Center (UDMC). On April 28, 1987, Teresita went to UDMC. Dr. Fredelicto ordered her admission and preparation for a D&C operation to be performed by his wife, Dr. Felicisima Flores, an obstetrician-gynecologist. Laboratory tests were ordered. Before the operation at 2:40 p.m., Dr. Felicisima met the patient, conducted an examination, and called the laboratory. Only partial results were available, showing a blood sugar level of 10.67mmol/l. Dr. Felicisima proceeded with the D&C, with Dr. Fredelicto administering anesthesia. The complete laboratory results, available the next day, showed a very high sugar level in the urine (+++). Teresita was placed under an internist. Her condition worsened, and she was diagnosed with Diabetes Mellitus Type II. She died on May 6, 1987. The heirs of Teresita filed a damages suit against the spouses Flores and UDMC, alleging medical negligence. The Regional Trial Court ruled for the plaintiffs, a decision affirmed with modification by the Court of Appeals. The spouses Flores appealed to the Supreme Court.

ISSUE

Whether the petitioner spouses, Dr. Fredelicto Flores and Dr. Felicisima Flores, were negligent in their management of Teresita Pineda’s case, particularly in proceeding with the D&C operation without first addressing her diabetic condition.

RULING

The Supreme Court DENIED the petition and AFFIRMED the findings of negligence. The Court held that the elements of a medical negligence case—duty, breach, injury, and proximate causation—were present. The physicians had a duty to adhere to the standard of care of a reasonably competent doctor. They breached this duty by proceeding with the elective D&C operation despite clear warning signs of diabetes. As early as the first consultation, diabetes was suspected. Before the operation, the available blood sugar result (10.67mmol/l) was significantly elevated, strongly indicating diabetes. The physicians failed to wait for the complete laboratory results, particularly the urinalysis, which would have confirmed the condition. Expert testimony established that performing surgery on an undiagnosed and uncontrolled diabetic patient greatly increases the risks of complications, including infection and poor wound healing. The D&C, being an elective procedure for abnormal vaginal bleeding, was not an emergency that justified proceeding without first stabilizing the patient’s diabetic condition. This breach was the proximate cause of Teresita’s subsequent complications and death. The mistake was not an honest error in judgment but a failure to observe the standard of pre-operative care. The Court modified the damages, awarding the heirs P50,000.00 as civil indemnity for death, P400,000.00 as moral damages, P100,000.00 as exemplary damages, and P36,000.00 as actual damages. The award of attorney’s fees was deleted.