Cayao-Lasam v. Ramolete
REITERATIONFacts
1. The Antecedents: On July 28, 1994, Editha Ramolete, then three months pregnant, was admitted to Lorma Medical Center due to vaginal bleeding. Following the petitioner's telephone advice, Editha underwent a Dilatation and Curettage (D&C) procedure on July 30, 1994. Approximately six weeks later, on September 16, 1994, Editha was readmitted to the hospital suffering from severe abdominal pains, vomiting, and was found to have a ruptured uterus and massive intra-abdominal hemorrhage, necessitating a hysterectomy, which rendered her unable to bear children. The respondents alleged that Editha's condition was a result of the petitioner's negligence during the D&C procedure and her failure to remove the fetus. 2. Procedural History: On November 7, 1994, the respondents filed a complaint for gross negligence and malpractice against the petitioner before the Professional Regulations Commission (PRC). The PRC's Board of Medicine initially exonerated the petitioner on March 4, 1999, finding that Editha suffered from an ectopic pregnancy interstitial, a condition not detectable by D&C. However, the PRC en banc reversed this decision on November 22, 2000, revoking the petitioner's license. The petitioner appealed to the Court of Appeals (CA), filing a Petition for Review under Rule 43 and a Petition for Certiorari under Rule 65. The CA dismissed the petition, holding that Rule 43 was improper as the PRC was not listed, and that a petition for certiorari was premature as the proper remedy was an appeal to the Office of the President under Republic Act No. 2382. 3. The Petition: The petitioner seeks review of the CA's decision via a Petition for Review on Certiorari under Rule 45 of the Rules of Court. The petitioner argues that the CA erred in holding that the PRC was excluded from Rule 43, that the CA should have treated the petition as a certiorari despite procedural issues, that respondents were not allowed to appeal to the PRC, and that the CA gravely abused its discretion by not ruling on the merits. The petitioner also contends that the PRC's decision violated her due process rights due to lack of notice and proof of service of the appeal memorandum, and that the PRC erred in revoking her license without sufficient expert testimony to establish the cause of Editha's injury, disregarding the Board of Medicine's findings and expert testimony presented by the petitioner.
Issue(s)
Whether the Court of Appeals erred in holding that the Professional Regulations Commission (PRC) is excluded from the quasi-judicial agencies contemplated under Rule 43 of the Rules of Civil Procedure. Whether the Court of Appeals erred in holding that a petition for certiorari was an improper and premature remedy. Whether respondents-spouses are allowed by law to appeal from the decision of the Board of Medicine to the Professional Regulations Commission. Whether the Court of Appeals committed grave abuse of discretion in denying the petition for review/petition for certiorari without ruling on the merits. Whether petitioner's right to due process was violated by the PRC's failure to notify her of the appeal proceedings and by the acceptance of the Memorandum on Appeal without proof of service. Whether the PRC committed grave abuse of discretion in revoking petitioner's license without expert testimony and by disregarding the Board of Medicine's findings, and whether medical malpractice was proven.
Ruling
The Supreme Court granted the petition, reversed and set aside the decision of the Court of Appeals, and affirmed the decision of the Board of Medicine exonerating petitioner. The Court ruled that appeals from the PRC should be filed with the Court of Appeals under Rule 43, and that the patient's failure to return for a follow-up check-up was the proximate cause of her injury.
Ratio Decidendi
On the issue of whether the Court of Appeals erred in holding that the PRC is excluded from Rule 43: The Supreme Court held that the Court of Appeals erred. While the PRC is not expressly enumerated in Section 1, Rule 43 of the Rules of Court, the rule applies to "any quasi-judicial agency in the exercise of its quasi-judicial functions." The enumeration is not exclusive. Furthermore, citing Yang v. Court of Appeals, the Court stated that Batas Pambansa Blg. 129 conferred upon the Court of Appeals exclusive appellate jurisdiction over appeals from decisions of the PRC. Therefore, the CA should have taken cognizance of the appeal. On the issue of whether the Court of Appeals erred in holding that a petition for certiorari was an improper and premature remedy: The Supreme Court agreed with the petitioner that the CA erred in dismissing the petition for review on procedural grounds without addressing the merits. The Court found that the CA should have taken jurisdiction over the appeal from the PRC decision. The CA's dismissal based on improper remedy prevented a review of the substantive issues, which the Supreme Court then proceeded to address. On the issue of whether respondents-spouses are allowed to appeal from the decision of the Board of Medicine to the PRC: The Supreme Court clarified that the right to appeal in administrative cases is statutory. While an earlier provision of the Rules and Regulations Governing the Regulation and Practice of Professionals might have created ambiguity, it was amended by Resolution No. 174, Series of 1990, to explicitly state that "the complainant/respondent may appeal the order, the resolution or the decision of the Board within thirty (30) days from receipt thereof to the Commission." Furthermore, later PRC rules (Resolution No. 06-342(A)) provide that "a party aggrieved" may appeal, indicating that both complainants and respondents have the right to appeal. On the issue of whether the Court of Appeals committed grave abuse of discretion in denying the petition without ruling on the merits: The Supreme Court found that the CA committed grave abuse of discretion by dismissing the petition on purely procedural grounds without delving into the substantive merits of the case. The CA's failure to review the PRC's decision meant that the petitioner was denied a proper appellate review of the adverse ruling against her. On the issue of whether petitioner's right to due process was violated: The Supreme Court found that the respondents failed to present proof of service of their Memorandum on Appeal to the petitioner before the PRC. This failure to notify the petitioner of the appeal proceedings violated her constitutional right to due process, rendering the proceedings before the PRC null and void. The Court cited EDI-Staffbuilders International, Inc. v. National Labor Relations Commission in support of this ruling. On the substantive merits of the case regarding medical malpractice and whether the PRC committed grave abuse of discretion in revoking petitioner's license: The Supreme Court held that medical malpractice requires proof of duty, breach, injury, and proximate causation. While a physician-patient relationship was established, the Court found no breach of duty. Expert testimony is essential to establish the standard of care and breach thereof. The Court noted that the respondents did not present expert testimony, while the petitioner presented Dr. Augusto M. Manalo, who testified that the D&C procedure was not the proximate cause of the uterine rupture. Dr. Manalo explained that the instrument could not reach the site of an ectopic pregnancy and that if the D&C caused the rupture, it would have occurred earlier. The Court also emphasized that the patient's failure to return for a follow-up check-up on August 4, 1994, as advised by the petitioner, interrupted the chain of continuity and was the proximate cause of her injury. This omission, rather than the petitioner's actions, led to the rupture of the uterus. The Court reiterated that doctors are not insurers against mishaps, especially when the patient fails to exercise proper diligence.
Main Doctrine
The Supreme Court affirmed the decision of the Board of Medicine exonerating Dr. Fe Cayao-Lasam, holding that the patient's own failure to return for a follow-up check-up, as advised, was the proximate cause of her injury, not the D&C procedure performed by the doctor. The Court also ruled that the Court of Appeals erred in dismissing the petition for review on procedural grounds, stating that appeals from the PRC should be filed with the CA under Rule 43.