
SUPREME COURT - SECOND DIVISION
[ G.R. No. 268308, April 02, 2025 ]
ELPIDIO QUE, PETITIONER, VS. PHILIPPINE HEART CENTER, DR. AVELINO P. AVENTURA, AND FIRST ASSOCIATED MEDICAL DISTRIBUTION CO., INC., RESPONDENTS.
Case Summary: Medical Malpractice & Informed Consent
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- This case involves a medical malpractice suit filed by the son of a patient who died after an unsuccessful, novel stenting procedure for an aortic aneurysm. The son sued the hospital, the primary doctor, and the device distributor. The Supreme Court affirmed the lower courts' dismissal of the complaint, finding no negligence. The Court held that the patient's death was a result of a known, inherent risk of the procedure, to which he had given his informed consent, and that the medical professionals acted according to the accepted standard of care.
- The Patient: Quintin Que was diagnosed with an aneurysm in his aortic arch, a life-threatening condition.
- The Procedure: His doctor at the Philippine Heart Center (PHC), Dr. Aventura, recommended a new, less invasive stenting procedure as an alternative to high-risk open-heart surgery. A foreign specialist, Dr. Verhoeven, was brought in to perform the operation.
- The Outcome: The procedure on February 14, 2000, was unsuccessful because the custom-built stent could not be deployed. Quintin suffered a stroke after the failed procedure and died 13 days later.
- The Lawsuit: Quintin's son, Elpidio Que, filed a complaint for damages, alleging medical negligence and lack of informed consent against the PHC, Dr. Aventura, and the stent distributor, FAMED.
- RTC Ruling: The RTC dismissed the complaint. It found no medical negligence, citing an autopsy report that classified the death as "natural" due to complications of his underlying disease. It also gave weight to signed consent forms.
- Court of Appeals (CA) Ruling: The CA affirmed the RTC's decision. It relied heavily on the testimony of two independent expert cardiovascular surgeons who stated that Dr. Aventura's advice was sound and that a stroke was a known, inherent risk of the procedure, regardless of its success.
- Did the doctors and the hospital commit medical negligence in their treatment of Quintin Que?
- Was there a lack of informed consent regarding the risks of the stenting procedure?
The Supreme Court DENIED the petition and AFFIRMED the lower courts' decisions.
- No Medical Negligence: The Court found that the petitioner failed to prove negligence. The expert testimonies presented by the defense established that the medical advice given was sound and the stenting procedure, despite its risks, was the more appropriate option compared to a highly invasive open-heart surgery.
- Informed Consent was Valid: The patient, Quintin Que, signed two separate consent forms acknowledging the risks of the procedure. The petitioner's claim that they were told the procedure was "virtually risk-free" was not substantiated. The Court emphasized that "less risk" does not mean "risk-free."
- Proximate Cause Not Proven: Expert testimony established that the patient's stroke and subsequent death were inherent risks of the catheter manipulation required for the procedure, which could have happened even if the stent had been successfully deployed. The death was not a direct result of negligence.
- Medical Malpractice: To prove medical malpractice, a patient must establish that the physician failed to observe the standard of care expected of a reasonably prudent doctor under similar circumstances, and that this failure was the proximate cause of the injury.
- Doctrine of Informed Consent: A physician has a duty to disclose material risks inherent in a proposed treatment to enable the patient to make an intelligent choice. A claim for lack of informed consent requires proving that the patient would not have consented to the treatment had the undisclosed information been provided.
- Role of Expert Testimony: In medical negligence cases, the testimony of expert witnesses (physicians in the same field) is crucial in establishing the standard of care and whether it was breached.