TORTS AND DAMAGES
OUR LADY OF LOURDES HOSPITAL vs SPOUSES ROMEO AND REGINA CAPANZANA
G.R. No. 189218, March 22, 2017, Sereno, CJ.
In an action for damages against a hospital, the negligence of its nurses can be imputed to the
employer where there is no proof that the employer exercised actual supervision and monitoring of
consistent compliance with hospital rules by its staff.
FACTS:
Regina Capanzana was brought to petitioner hospital for an emergency C-section. She successfully
gave birth to a baby boy. 13 hours after her operation, she asked for oxygen, and complained of a
headache, a chilly sensation, restlessness, and shortness of breath. It took around 10 minutes for
nurses to respond to the call and administer oxygen. She was eventually transferred to the
Intensive Care Unit, where she was hooked to a mechanical ventilator. When her condition still
showed no improvement, Regina was transferred to the Cardinal Santos Hospital. The doctors
thereat found that she was suffering from rheumatic heart disease mitral stenosis with mild
pulmonary hypertension. This development resulted in cardiopulmonary arrest and, subsequently,
brain damage. Regina lost the use of her speech, eyesight, hearing and limbs. She was discharged in
a vegetative state and eventually died.
Respondent spouses Capanzana filed a complaint for damages against petitioner hospital, along
with co-defendants: the nurses on duty. They allege that the nurses were negligent for not having
promptly given oxygen, and that the hospital was equally negligent for not making available and
accessible the oxygen unit on that same hospital floor.
ISSUE:
W/N petitioner hospital is negligent.
RULING:
YES. Proximate cause has been defined as that which, in natural and continuous sequence,
unbroken by any efficient intervening cause, produces injury, and without which the result would
not have occurred.The omission of the nurses - their failure to promptly check on Regina and to
refer her to the resident doctor and, thereafter, to immediately provide oxygen - was clearly the
proximate cause that led to the brain damage suffered by the patient.
As to the nurses: the RTC and CA found that there was a delay in the administration of oxygen to the
patient. When she was gasping for breath and turning cyanotic (bluish), it was the duty of the
nurses to intervene immediately by informing the resident doctor. Such high degree of care and
responsiveness was needed cannot be overemphasized because it takes only five minutes of oxygen
deprivation for irreversible brain damage to set in. Regina herself had asked for oxygen but even if
the patient had not asked for oxygen, the mere fact that her breathing was labored to an abnormal
degree should have impelled the nurses to immediately call the doctor and to administer oxygen.
They committed a breach of their duty to respond immediately to the needs of Regina. Regina
suffered from brain damage and the proximate cause of the brain damage was the delay in
responding to Regina's call for help and for oxygen.