In the case of St. Martin Polyclinic, Inc. v. LWV Construction Corporation, the Supreme Court ruled that a medical clinic cannot be held liable for damages based solely on a later medical finding of a disease in an overseas worker, without sufficient proof of negligence at the time of the initial medical examination. The court emphasized that negligence must be proven, not presumed, and that medical reports have a limited validity, not guaranteeing a worker’s health status indefinitely. This decision underscores the importance of establishing clear negligence to claim damages against medical facilities and highlights the limited scope of responsibility for pre-employment medical examinations.

When ‘Fit to Work’ Doesn’t Guarantee Future Health: Establishing Negligence in Medical Assessments

This case revolves around LWV Construction Corporation (LWV), a recruitment agency, and St. Martin Polyclinic, Inc., a medical clinic accredited to conduct pre-employment medical examinations. LWV referred Jonathan Raguindin to St. Martin for a medical check-up before deploying him to Saudi Arabia. St. Martin declared Raguindin “fit for employment” in a report issued on January 11, 2008. Based on this report, LWV proceeded with Raguindin’s deployment, incurring expenses amounting to P84,373.41. However, upon arrival in Saudi Arabia, Raguindin tested positive for the Hepatitis C virus (HCV), leading to his repatriation. LWV sued St. Martin, claiming that the clinic’s negligence in issuing an inaccurate medical report caused them financial losses. The core legal question is whether St. Martin Polyclinic was negligent in its medical assessment, thus liable for damages.

The Metropolitan Trial Court (MeTC) initially ruled in favor of LWV, ordering St. Martin to pay actual damages and attorney’s fees. This decision was affirmed by the Regional Trial Court (RTC). However, the Court of Appeals (CA) modified the ruling, deleting the award for actual damages due to lack of evidence but awarding temperate damages of P50,000.00. The CA reasoned that St. Martin failed in its duty to accurately diagnose Raguindin’s condition. Dissatisfied, St. Martin elevated the case to the Supreme Court, arguing that they were not negligent and that LWV failed to properly prove their claim.

The Supreme Court approached the case by examining the principles of quasi-delict under Article 2176 of the Civil Code, which establishes liability for damages caused by negligence. The elements of a quasi-delict are: (1) an act or omission; (2) negligence; (3) injury; (4) a causal connection between the negligent act and the injury; and (5) no pre-existing contractual relation. Furthermore, the Court addressed the interplay between Article 2176 and Articles 19, 20, and 21 of the Civil Code, which deal with abuse of rights and acts contrary to law or morals. Justice Leonen’s opinion in Alano v. Magud-Logmao clarifies that Article 2176 applies when the negligent act does not breach an existing law or contract, while Article 20 concerns violations of existing law as the basis for injury.

Article 2176. Whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of this Chapter.

Building on this principle, the Court emphasized that negligence must be proven, not presumed. The test for determining negligence is whether the defendant used reasonable care and caution that an ordinarily prudent person would have used in the same situation. According to Picart v. Smith, the standard is objective, based on what a reasonable person would do given the circumstances. In this case, the burden of proof rested on LWV to demonstrate that St. Martin was negligent in conducting the medical examination and issuing the “fit to work” report.

The Supreme Court found that LWV failed to provide sufficient evidence of St. Martin’s negligence. LWV primarily relied on the certification from the General Care Dispensary in Saudi Arabia and the HCV Confirmatory Test Report, which indicated Raguindin tested positive for HCV. However, these tests were conducted two months after St. Martin issued its medical report. The Court noted that the later diagnosis did not conclusively prove that Raguindin had HCV at the time of the initial examination. Therefore, LWV needed to demonstrate that St. Martin failed to observe standard medical procedures or that there were palpable signs of Raguindin’s unfitness at the time of the examination.

This approach contrasts with the CA’s view, which suggested that St. Martin should have detected the HCV. The Supreme Court reasoned that HCV’s incubation period and asymptomatic nature in its early stages made it plausible that Raguindin contracted the virus after his medical examination in the Philippines. The Court also addressed the expiration date on St. Martin’s medical report, clarifying that it did not serve as a guarantee of Raguindin’s health status during that entire period. Instead, it only indicated the report’s validity for submission purposes. Therefore, expecting St. Martin to predict or assure Raguindin’s unchanging medical condition was unreasonable.

Did the defendant in doing the alleged negligent act use that reasonable care and caution which an ordinarily prudent person would have used in the same situation? If not, then he is guilty of negligence.

Furthermore, the Supreme Court highlighted procedural errors in the lower courts’ acceptance of evidence. The Certification from the General Care Dispensary was written in an unofficial language and lacked a translation into English or Filipino, violating Section 33, Rule 132 of the Rules of Court. Additionally, LWV failed to prove the due execution and authenticity of this private document, as required by Section 20, Rule 132. Similarly, the HCV Confirmatory Test Report from Saudi Arabia, while a public document, was not properly authenticated according to Section 24, Rule 132. These procedural lapses further weakened LWV’s case.

The Supreme Court ultimately concluded that LWV did not provide credible and admissible evidence to prove St. Martin’s negligence. The lower courts erred in admitting unauthenticated foreign documents and in presuming negligence without concrete evidence. The decision emphasizes the importance of adhering to evidentiary rules and establishing a clear link between the alleged negligence and the resulting injury. Thus, the Supreme Court reversed the CA’s decision and dismissed LWV’s complaint for lack of merit.

FAQs

What was the key issue in this case?	The key issue was whether St. Martin Polyclinic was negligent in issuing a medical report declaring Jonathan Raguindin “fit for employment,” leading to LWV Construction Corporation incurring damages when Raguindin later tested positive for Hepatitis C in Saudi Arabia. The court examined whether LWV presented sufficient evidence to prove negligence on St. Martin’s part.
What did the Court rule regarding the burden of proof for negligence?	The Court ruled that negligence must be proven, not presumed. LWV, as the plaintiff, had the burden of proving that St. Martin failed to exercise reasonable care and caution in conducting the medical examination.
Why was the Certification from the General Care Dispensary deemed inadmissible?	The Certification was deemed inadmissible because it was written in an unofficial language without a proper translation into English or Filipino, violating Section 33, Rule 132 of the Rules of Court. Additionally, LWV failed to prove its due execution and authenticity as a private document.
What was the significance of the HCV Confirmatory Test Report from Saudi Arabia?	While the report was considered a public document, it was not properly authenticated according to Section 24, Rule 132 of the Rules of Court. LWV did not provide a certificate from the Philippine embassy or consulate in Saudi Arabia, authenticating the document with the official seal.
How did the Court interpret the expiration date on the medical report?	The Court clarified that the expiration date did not guarantee Raguindin’s health status until that date. It only meant the report was valid for submission as a formal requirement for overseas employment.
What is the difference between Article 2176 and Articles 19, 20, and 21 of the Civil Code?	Article 2176 governs quasi-delicts where there is no pre-existing contractual relationship or violation of a law. Articles 19, 20, and 21 cover acts done with abuse of rights or contrary to law or morals, requiring a specific violation of law or moral standard.
What is the test for determining negligence, according to the Court?	The test is whether the defendant used reasonable care and caution that an ordinarily prudent person would have used in the same situation. This is an objective standard based on what a reasonable person would do under similar circumstances.
Could St. Martin have been expected to guarantee Raguindin’s health?	No, the Court reasoned that St. Martin could not have been reasonably expected to predict or guarantee that Raguindin’s medical status of being fit for employment would remain unchanged, especially given the incubation period and asymptomatic nature of HCV.

This case serves as a reminder that claims of medical negligence require solid evidence demonstrating a breach of duty and a direct link to the resulting harm. It is not enough to simply point to a later diagnosis; the plaintiff must prove that the medical provider failed to meet the standard of care at the time of the examination. This decision protects medical professionals from unsubstantiated claims while reinforcing the need for thorough and careful medical assessments.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: St. Martin Polyclinic, Inc. v. LWV Construction Corporation, G.R. No. 217426, December 04, 2017