Manila Doctors Hospital vs.

So Un Chua et al
GR no. 150355 | July 31, 2006
Ponente: J. Austria-Martinez

Facts:

Manila Doctors Hospital (petitioner) filed a complaint for a sum of money against So Un Chua and Vicky
Ty (respondents) before the Regional Trial Court (RTC) of Manila. The case stemmed from unpaid
hospital bills amounting to over one million pesos incurred by the respondents for medical services
rendered to Vicky Ty.

Issue:

The main issue in this case revolved around the prescription period applicable to the petitioner's claim
for payment of medical services rendered to the respondents.

Ruling:

The Supreme Court, in its decision dated July 31, 2006, affirmed the RTC's judgment. It held that the
action filed by the petitioner was indeed barred by prescription. The Court explained that the applicable
law was Article 1144 of the Civil Code, which prescribes a four-year period for actions based on an
obligation arising from law. The Court noted that the medical services were rendered to Vicky Ty back in
1990, while the complaint was filed only in 1997. As such, the action had already prescribed before it
was filed. The Court rejected the petitioner's argument that the claim was based on a quasi-delict since
it involved medical negligence, stating that the cause of action was contractual in nature. Therefore, the
Court ruled in favor of the respondents, stating that the petitioner's claim was indeed barred by
prescription, and the RTC's judgment was affirmed.