Paolo Anthony C. de Jesus v. Dr. Romeo F. Uyloan

Summary

Patient sued doctors and hospital for medical malpractice, claiming breach of contract to invoke longer prescriptive periods instead of the four-year period for quasi-delict. The Supreme Court ruled that medical malpractice actions require express promises for specific results to be treated as contract-based. Without such express agreement, the action sounds in tort under Article 2176 (quasi-delict) with a four-year prescriptive period under Article 1146. Since the complaint was filed over five years after the September 15, 2010 operation, it was time-barred. The decision clarifies that physician-patient relationships, while consensual, do not automatically create contractual liability absent express promises to cure or achieve specific medical results.