Manila Doctors Hospital vs.
So Un Chua and Vicky Ty
G.R. 150355, Jule 31, 2006
Facts:
- December 13, 1993: Respondents filed a complaint claiming that respondent So Un Chua, mother of
respondent, Vicky Ty, was admitted in petitioner hospital for Hypertension and Diabetes.
- While she was confined, Judith Chua, Ty’s sister was likewise confined for injuries suffered in a vehicular
accident.
- Partial payments (P435,800.00) were made for hospital bills but after the discharge of Judith Chua, So Un
Chua remained in confinement accumulating more hospital bills.
- Ty said that she will settle the bills as soon as funds become available and that the bills be directed to her.
- However, she claimed that these pleas were unheeded and the latter even threatened to implement unpleasant
measures (e.g. removal of the air conditioner, refrigerator, telephone line, television, etc) which worsened the
respondents condition. (Which we will eventually find out not to be true)
- Respondent then prayed for the award of damages.
- Petitioner filed a counterclaim, denied the above facts and argued the following:
o As early as one week after Chua was admitted, Dr. Rody Sy, her attending physician said she could
already be discharged but respondents insisted otherwise.
o They gave medical examinations all yielding the conclusion that Chua could already be discharged.
o Respondent Ty voluntarily undertook to pay the hospital bills for both patients but failed to make good
on such commitment in violation of the Contract for Admission and Acknowledgment of
Responsibility for Payment which she executed.
o Ty also signed a promissory note for the remaining balance of about P1 M and issued postdated checks
to cover it.
o The bills were sent to Ty but she intentionally evaded the hospital staff.
o The removal of certain appliances were resorted to as cost-cutting measures to minimize respondents
charges that were already piling up.
o Finally, petitioner claimed that respondents filed this civil case as leverage against it after the hospital
filed a criminal case for violation of BP 22.
o The hospital asked for damages as well.
- RTC: Ruled in favor of respondents finding that the removal of the facilities triggered the hypertension of
Chua and that the hospital acted in bad faith in removing them without prior notice.
- CA: affirmed the RTC decision (with modification to amount of damages)
- SINCE THE CASE DIDN’T EXPLICITLY MENTION ARTICLES 19-21, I INFERRED NA THE BONE OF
CONTENTION WAS THE LOWER COURT’S RULING ESSENTIALLY SAYING THAT THE
PETITIONER’S ACTUATIONS “when it removed the facilities, were oppressive, unnecessary and antisocial,
done in bad faith without proper notice and with no other intention but to harass respondents, all of which
constitute an abuse of rights.”
Issues: W/N the actuations of petitioner amount to actionable wrongs
Held: No.
The operation of private hospitals is impressed with public interest and imbued with heavy social responsibility but the
hospital is also a business; and as a business, it has a right to institute all measures of efficiency commensurate to the
ends for which it is designed.
In the institution of cost-cutting measures, the hospital has a right to reduce the facilities and services that are deemed
to be non-essential, such that their removal would not be detrimental to the medical condition of the patient.
Thus, the SC said that the following questions had to be addressed: a.) W/N the subject facilities in this case are non-
essential and b.) W/N petitioner observed the diligence of a good father of the family in ascertaining the possible
repercussions of the removal of these facilities prior to actual removal.
The SC answered yes to both questions; the facilities were non-essential and the hospital exercised due diligence in
ascertaining such fact.
Though human experience would show that deactivation of the air-conditioner may cause physical discomfort, or the
removal of television and telephones may cause exasperation, not every suppression of the things one has grown
accustomed to amounts to an actionable wrong, nor does every physical or emotional discomfort amount to the kind of
anguish that warrants an award of damages.
The underlying basis for the award of tort damages is the premise that an individual was injured in contemplation of
law. Thus, there must first be the breach of some duty and the imposition of liability for that breach.
Contrary to respondents contention that the removal of the facilities triggered Chua’s hypertension, Dr. Sy
categorically stated that during his daily rounds, he was certain that her blood pressure were within acceptable limits.
Sister Galeno, the Administrator of the hospital also said that she knew the condition of ventilation of the patient’s
deluxe room and said that ventilation was not a problem (considering there was a large grilled window which could be
opened).
Further, the staff of petitioner took proactive steps to inform the relatives of the removal of facilities prior thereto but
the latter evaded them as not wanting to pay for the hospital bills.
The medical condition of respondent was also consistently monitored by Dr. Sy, a cardiologist said to be a very good
doctor by the respondents themselves. In fact, Dr. Sy requested several medical exams done with the consent of the
family, even calling on other specialists, all finding that her illnesses were lifelong illnesses at a stage where they could
not be totally removed but that her condition was nonetheless, not serious.
Other contentions of the respondents as to delay in delivery of food and barring of midwives or respondent’s suffering
from depressing were bereft of evidentiary basis.
Evidence therefore overwhelmingly demonstrates that respondent Chua had been adequately attended to.
Extra?* Re: Detention in hospital
While witnesses for the petitioner stated as the patient cannot leave the hospital without the discharge, clearance or
gate pass issued only after the settlement of the bills is made, it must be understood that there are only demonstrative of
the precondition that a patient cannot step out of the premises without the consent of the hospital. However, even
without its consent, the patient can still leave anytime as a matter of policy.
Petitioner as private hospital is also a business. By warning respondents that it shall withhold clearance, it was simply
exercising its right to protest against an absconding patient as precursor to avail of other appropriate legal remedies. In
fact, it was even the respondents who opted not to leave because of their own promise not to leave unless the bills were
fully settled.
Legal authorities provided that a patient cannot be detained in a hospital for non-payment of the bill. If the patient
cannot pay, the law provides a remedy which is to file the necessary suit in court for recovery of such amount. If the
patient is prevented from leaving, any person acting in his behalf can apply in court for a writ of habeas corpus.
The Court also said that “it does not constitute a trespass to the person to momentarily prevent him from leaving the
premises because he refuses to comply with some reasonable condition subject to which he entered them.”
