St. Martin Polyclinic v. Lwv Construction Corporation

Summary

This case involves a dispute between a medical clinic and a recruitment agency over alleged negligent medical examination. LWV Construction Corporation sued St. Martin Polyclinic for damages after a worker declared 'fit for employment' by the clinic in January 2008 later tested positive for hepatitis C in Saudi Arabia in March-April 2008. The lower courts initially ruled in favor of LWV, awarding damages. However, the Supreme Court reversed, holding that LWV failed to prove the clinic's negligence. The Court found that testing positive for HCV months after the medical examination does not establish that the worker was already infected at the time of the clinic's examination, given that HCV has an incubation period of 2 weeks to 6 months and is often asymptomatic. The Court also found that key foreign documentary evidence was improperly admitted without proper authentication and translation. The case clarifies the application of quasi-delict provisions under Article 2176 of the Civil Code and emphasizes the burden of proving negligence in professional medical services.