Our Lady of Lourdes Hospital v. Spouses Romeo

Summary

This medical malpractice case involved Regina Capanzana who suffered brain damage following an emergency C-section at Our Lady of Lourdes Hospital in December 1997. The patient experienced post-operative complications including shortness of breath and requested oxygen, but nurses allegedly delayed their response by approximately 10 minutes. This delay resulted in hypoxic encephalopathy causing permanent brain damage and eventual vegetative state until her death in 2005. The Supreme Court affirmed the Court of Appeals' decision holding the hospital liable under the doctrine of vicarious liability for the negligence of its nurses, finding that while the hospital proved due diligence in selection of employees, it failed to demonstrate adequate supervision. The Court rejected the hospital's defense that the patient's condition was caused by unpreventable amniotic fluid embolism, ruling instead that the nurses' delayed response was the proximate cause of the brain damage. The case establishes important precedent regarding hospital corporate responsibility and the burden of proving due diligence in both selection and supervision of medical staff.