**Facts:**
Spouses Eva Marie and Noel Benedicto Ronquillo, unable to conceive, sought medical advice from Dr. Concepcion Ilao-Oreta, a recognized obstetrician-gynecologist and the chief of the Reproductive Endocrinology and Infertility Section at St. Luke’s Medical Center. Dr. Ilao-Oreta recommended a laparoscopic procedure to investigate the cause of infertility, scheduled for April 5, 1999. However, Dr. Ilao-Oreta, having traveled to Hawaii for her honeymoon, failed to consider the time difference and consequently did not return in time for the procedure. This led the Ronquillo spouses to file a complaint for breach of professional service contract and damages against Dr. Ilao-Oreta and St. Luke’s Medical Center. The trial court awarded actual damages, while the Court of Appeals found Dr. Ilao-Oreta grossly negligent, modifying the award to include moral and exemplary damages, attorney’s fees, and increased actual damages. Dr. Ilao-Oreta petitioned for review to the Supreme Court.
**Issues:**
1. Whether Dr. Ilao-Oreta’s action constituted gross negligence.
2. The entitlement of the Ronquillo spouses to moral and exemplary damages.
3. Appropriateness of awarding attorney’s fees.
4. Assessment of actual damages due to alleged breach.
**Court’s Decision:**
The Supreme Court differentiated gross negligence from mere negligence, concluding that Dr. Ilao-Oreta’s failure to attend the procedure did not constitute gross negligence. The Court ruled that Dr. Ilao-Oreta had taken steps showing an intention to perform the procedure and made efforts to rectify her absence upon realization, which reflected negligence but not to the extent of gross negligence. Consequently, the Ronquillo spouses were not entitled to moral damages, as their case did not involve circumstances justifying such an award. Similarly, the absence of actions in a wanton, fraudulent, reckless, oppressive, or malevolent manner by Dr. Ilao-Oreta negated the provision for exemplary damages and attorney’s fees. Finally, the Court adjusted the award for actual damages to P2,288.70, citing insufficient substantiation for other claims.
**Doctrine:**
Gross negligence is characterized by a want of even slight care, acting with a conscious indifference to consequences in so far as other persons may be affected. It is differentiated from mere negligence by its severity and the apparent lack of concern for the potential impact of one’s actions on others.
**Class Notes:**
– **Negligence vs. Gross Negligence:** Understand the difference in severity and outcomes between negligence and gross negligence, especially in professional liability cases.
– **Damages:** Recognize when moral and exemplary damages may be awarded, emphasizing the need for malicious intent or gross negligence for such awards.
– **Actual Damages:** Learn the importance of substantiating claims with adequate, competent proof, as demonstrated in the computation and adjustment of actual damages awarded.
– **Interest Awards:** Note that interest on actual damages can be applied from the time of complaint filing and adjusted post-judgment until satisfaction is achieved, illustrating the process of compensation over time.
**Historical Background:**
This case reflects the legal responsibilities of medical professionals in managing their schedules and the implications of failing to fulfill professional commitments. It emphasizes the fine line between negligence and gross negligence within the context of Philippine legal standards, highlighting accountability in professional services and the measurement of damages related to service contracts.
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