- Petitioner
- St. Martin Polyclinic
- Respondent
- Lwv Construction Corporation
- Citation
- G.R. No. 217426
- Court
- Supreme Court
- Division
- Second Division
- Ponente
- Perlas-Bernabe, J.
- Decided
- December 4, 2017
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.
Intellegal Wiki · Key Holding
Granted the petition and reversed the CA, holding that the claim was governed by Article 2176 (quasi-delict) rather than Articles 19, 20, and 21, and that the respondent failed to prove the clinic's negligence through credible and admissible evidence; the complaint was dismissed for lack of merit.
An editorially maintained summary of the rule this Supreme Court decision is cited for — not legal advice.