Ruñez, Jr. vs. Jurado

A physician is not administratively liable for simple neglect of duty for failing to track down a patient who voluntarily leaves against medical advice, because a doctor's duty does not extend to forcing compliance or seeking out patients who exercise their right to disregard medical recommendations.

Samuel V. Ruñez, Sr., a driver for the Supreme Court Motorpool, presented at the Court's clinic with dizziness and a critically high blood pressure of 210/100 mmHg. He was treated by Dr. Marybeth V. Jurado, Medical Officer IV. After initial emergency treatment, Ruñez, Sr. left the clinic on his own to look for a companion, failed to return, and subsequently suffered a stroke and died. His son, Samuel R. Ruñez, Jr., filed an administrative complaint against Dr. Jurado for lack of attention and neglect.

• The Clinic Visit: On January 12, 2005, at around 4:20 p.m., Ruñez, Sr. arrived alone at the Supreme Court clinic complaining of dizziness. The reception nurse recorded his blood pressure at 210/100 mmHg and his pulse rate at 112 beats per minute.
• Disputed Events Inside the Clinic: Complainant alleged that Dr. Jurado merely advised Ruñez, Sr. to go to the hospital and allowed him to walk out alone. Dr. Jurado maintained that, upon being informed of the vital signs, she instructed the nurse to administer one tablet of Capoten 25mg to quickly lower his blood pressure, informed Ruñez, Sr. that he would be taken to the hospital, and ordered the ambulance driver to stand by. Minutes later, after his condition temporarily stabilized, Ruñez, Sr. stood up and walked out, stating he was looking for a companion. Dr. Jurado instructed a male nurse to look for him, but he could not be located.
• Subsequent Medical Events: Ruñez, Jr. rushed his father to the Manila Doctors Hospital, where he was treated in the emergency room and discharged at 8:30 p.m. On the way home, Ruñez, Sr. experienced nausea and palpitations, necessitating a return to the hospital at 10:00 p.m. A C.T. Scan revealed a blood clot. The following morning, he suffered a stroke, went on flat line, was revived, and was transferred to the ICU. He never recovered and died on September 12, 2005.
• Investigating Officer's Findings: Atty. Candelaria gave credence to Dr. Jurado's version of the events inside the clinic, supported by clinic personnel affidavits. However, she found Dr. Jurado's actions after Ruñez, Sr. left to be less than the required diligence of a good father of a family, noting that Dr. Jurado left the clinic at 4:31 p.m. without personally searching for the patient, informing his relatives, or turning his case over to another doctor.

• Neglect in Treatment: Petitioner argued that Dr. Jurado merely advised his father to go to the hospital and allowed him to travel to the hospital alone despite the availability of an ambulance at the clinic's disposal.
• Causation: Petitioner maintained that his father would not have suffered a stroke if not for Dr. Jurado's neglect.

• Proper Treatment Administered: Respondent countered that she administered emergency medication (Capoten 25mg), informed Ruñez, Sr. of the need for hospitalization, and placed the ambulance on standby for his conduction.
• Patient's Voluntary Departure: Respondent argued that Ruñez, Sr. left the clinic of his own volition to find a companion and failed to return, making his subsequent deterioration a result of his own failure to follow medical advice.

• Administrative Liability: Whether Dr. Jurado is administratively liable for simple neglect of duty arising from her failure to search for Ruñez, Sr. or inform his relatives after he voluntarily left the clinic.

• Administrative Liability: No administrative liability was found. Simple neglect of duty requires a failure to give proper attention to a task expected of an employee. The standard of care for physicians is the reasonable skill and competence ordinarily employed by the profession under similar conditions, which Dr. Jurado fulfilled when she treated Ruñez, Sr. inside the clinic. After the patient left, there was no expected task to track him down or force compliance. A patient cannot attribute damages to a physician resulting from the patient's own failure to follow medical advice. Because a person is the master of his own body, a physician has no power to force a patient to stay under care (save for exceptions like communicable diseases or court orders), and thus no duty to seek out a patient who voluntarily disregards medical directives.

• Standard of Care for Physicians — A physician is expected to apply that degree of care and skill ordinarily employed by the medical profession generally under similar conditions. The standard is reasonable skill and competence, not extraordinary care. Applied to rule that Dr. Jurado met this standard when she treated Ruñez, Sr. inside the clinic.
• Patient Autonomy / Leaving Against Medical Advice — A patient cannot attribute damages to a physician resulting from the patient's failure to follow medical advice. If a patient leaves contrary to instructions, the physician is not liable for subsequent events. There is no expectation for doctors to track down patients who miss appointments or force them to comply with directives. Applied to rule that Dr. Jurado had no duty to search for Ruñez, Sr. or force him to stay after he voluntarily walked out of the clinic.

• "A doctor’s duty to his patient is not required to be extraordinary. The standard contemplated for doctors is simply the reasonable average merit among ordinarily good physicians, i.e. reasonable skill and competence."
• "If a patient leaves the hospital contrary to instructions, the physician is not liable for subsequent events. There is no expectation from doctors that they track down each patient who apparently missed their appointments or force them to comply with their directives. After all, a person is still the master of his own body."

• Philippine Retirement Authority v. Rupa, 363 SCRA 480 (2001) — Cited for the definition of simple neglect of duty and examples of acts constituting it, establishing that such neglect presupposes a task expected of an employee.
• Reyes v. Sisters of Mercy Hospital, 341 SCRA 760 (2000) — Cited for the standard of care expected of physicians, which is the degree of care and skill ordinarily employed by the profession generally under similar conditions.
• Carey v. Mercer, 132 N.E. 353 — Cited for the proposition that a patient cannot attribute damages to a physician resulting from the patient's own failure to follow advice.
• Feltman v. Dunn, 217 N.W. 198 — Cited for the rule that a physician is not liable for subsequent events if a patient leaves contrary to instructions.

• Article II, Section 1, Code of Medical Ethics of the Medical Profession in the Philippines — Provides that a physician should attend to patients faithfully and conscientiously, securing all possible benefits dependent on professional skill and care. Applied to establish the baseline ethical duty, which was fulfilled when Dr. Jurado treated Ruñez, Sr. inside the clinic.
• Republic Act No. 3573 — Cited as an exception where doctors have the authority to compel treatment, specifically for compulsory treatment due to communicable diseases.

Hilario G. Davide Jr. (CJ), Reynato S. Puno, Artemio V. Panganiban, Leonardo A. Quisumbing, Consuelo Ynares-Santiago, Angelina Sandoval-Gutierrez, Antonio T. Carpio, Ma. Alicia Austria-Martinez, Renato C. Corona, Conchita Carpio Morales, Romeo J. Callejo, Sr., Dante O. Tinga, Minita V. Chico-Nazario, Cancio C. Garcia.