St. Martin Polyclinic, Inc. v. LWV Construction Corporation
REITERATIONFacts
The Antecedents: Respondent LWV Construction Corporation referred prospective applicant Jonathan V. Raguindin to petitioner St. Martin Polyclinic, Inc. for a pre-deployment medical examination. Petitioner issued a Medical Report dated January 11, 2008, clearing Raguindin as "fit for employment." Respondent deployed Raguindin to Saudi Arabia, incurring expenses. Subsequently, Raguindin underwent a medical examination in Saudi Arabia on March 24, 2008, where he tested positive for Hepatitis C Virus (HCV). A re-examination on April 28, 2008, confirmed the positive result, leading to Raguindin's repatriation. Procedural History: Respondent filed a complaint for sum of money and damages against petitioner, alleging recklessness in issuing the medical report. The Metropolitan Trial Court (MeTC) ruled in favor of respondent, awarding actual damages and attorney's fees. The Regional Trial Court (RTC) affirmed the MeTC decision. The Court of Appeals (CA) affirmed the RTC decision with modification, deleting actual damages and awarding temperate damages of P50,000.00, finding that petitioner failed to accurately diagnose Raguindin. The Petition: Petitioner filed a petition for review on certiorari, assailing the CA's decision and resolution, arguing that it was not negligent and that the evidence presented by respondent was inadmissible.
Issue(s)
Whether petitioner was negligent in issuing the Medical Report declaring Raguindin "fit for employment." Whether the evidence presented by respondent, particularly the Certification from the General Care Dispensary and the HCV Confirmatory Test Report, were admissible and had probative value.
Ruling
The petition is GRANTED. The Decision dated July 11, 2014, and the Resolution dated February 27, 2015, of the Court of Appeals are REVERSED and SET ASIDE. The complaint of respondent LWV Construction Corporation is DISMISSED for lack of merit.
Ratio Decidendi
On the issue of negligence: The Supreme Court held that respondent failed to prove petitioner's negligence. The Court emphasized that negligence must be proven by him who alleges it, and it cannot be presumed. The evidence presented by respondent, namely the Certification dated April 28, 2008, and the HCV Confirmatory Test Report, only indicated the results of examinations conducted months after petitioner's medical report was issued. The Court noted that the incubation period for HCV is two to six months, and Raguindin could have contracted the virus after his examination in the Philippines. The expiration date of the medical report did not constitute a guarantee of Raguindin's condition until that date, as intervening factors could have altered his health status. Therefore, there was no convincing proof that Raguindin was already positive for HCV at the time petitioner issued its report. On the admissibility and probative value of evidence: The Court found that the Certification issued by the General Care Dispensary should not have been admitted as evidence because it was written in an unofficial language without a translation into English or Filipino, as required by Section 33, Rule 132 of the Rules of Court. Furthermore, its due execution and authenticity were not proven in accordance with Section 20, Rule 132, as the author was not presented in court, rendering it hearsay evidence. The HCV Confirmatory Test Report, while potentially a public document, was also inadmissible because it was not duly authenticated in accordance with Section 24, Rule 132 of the Rules of Court, lacking the required certificate from a Philippine foreign service officer stationed in Saudi Arabia. The Court clarified that questioning the validity of these documents did not constitute a change in the theory of the case, as petitioner had raised these issues in its position paper before the MeTC.
Main Doctrine
The Supreme Court reversed the Court of Appeals, holding that the petitioner was not negligent in issuing a medical report clearing an applicant for employment, as the subsequent diagnosis of Hepatitis C virus (HCV) occurred months after the examination and could have been contracted thereafter. The Court also emphasized the importance of proper authentication and translation of foreign documents as evidence.