Hospitals' liability for injuries and deaths of patients

The management of hospitals, more than the administration of universities, colleges, and manufacturing companies, is a very tough and risky job. Lives are involved and it’s extremely difficult to supervise doctors, nurses, dentists, and other hospital staff.

Disgruntled patients and families may file cases of damages for deaths, injuries, or other forms of damages to patients admitted by hospitals. In the case of OLLH versus Spouses Capanzana (GR 189218) decided by the Supreme Court on March 22, 2017, the hospital was held liable due to the negligence of the nurse who failed to provide oxygen to a patient who experienced breathing difficulties. That patient became comatose and vegetative. That was one day after the patient delivered a baby, and after she was discharged from the recovery room and brought to an ordinary room. She complained of headache, chills, and shortness of breath. She asked for oxygen. The nurse allowed 10 minutes to lapse before oxygen was provided.

The patient was found suffering from pulmonary edema after an X-ray. She was brought to the ICU and attached to a mechanical ventilator. She then suffered brain damage. She was transferred to another hospital. She was found to have suffered from rheumatic heart, mitral stenosis, and mild pulmonary hypertension. This resulted to a cardio-pulmonary arrest, and subsequently brain damage, loss of speech, eyesight, hearing, and use of limbs. She was discharged in a vegetative state. The spouses filed a complaint for damages in 1998. The trial court held the hospital and the nurse liable for failure to act immediately leading the serious damage to the patient’s health.

The appellate court held that the proximate cause of the patient's condition was hypoxic encephalopathy, a diffused brain secondary to lack of oxygen. The Court of Appeals said the hospital should be held liable based on the doctrine of corporate responsibility. The hospital failed to prove that it exercised due diligence in supervising its nurses. The fact that there was no oxygen in the floor, where the patient was confined, was evidence of negligence on the part of the hospital. The Supreme Court affirmed with modification, blaming the hospital for its failure. This should be a lesson for all hospital administrators and nurses.

The court ruled: "We agree with the courts below that when she was gasping for breath and turning cyanotic, it was the duty of the nurses to intervene immediately by informing the resident doctor. Had they done so, proper oxygenation could have been restored and other interventions performed without wasting valuable time. That such high degree of care and responsiveness was needed cannot be overemphasized- considering that it takes only five minutes of oxygen deprivation for irreversible brain damage to set in.” For these, the hospital was condemned to pay actual damages, compensatory damages, moral damages, exemplary damages, attorney's fees, and legal interests on all the monetary awards until full payment.

The life of the patient can never be restored. But the behavior of hospital managers and staff can be modified. No one wants such tragedies as this. Had there been enough prudence and focus on the job, all the pains and sufferings could have been avoided. We shall continue this series if only to educate all concerned; the hapless victims and the reckless offenders.