Republic of the Philippines}
City of Taguig}
COMPLAINT AFFIADVIT
I, Clara Bueno, Filipino, of legal age, married, a resident of 38th St, Taguig,
Metro Manila, having been sworn in accordance with the law, hereby depose and
say that:
1. On 11 September 2014 at around 6AM, my 16 year old son, Eduardo
Bueno was involved in a vehicular accident along SLEX.
2. Dr. Doctor was driving to Mercy Hospital that morning and saw the whole
thing. He immediately put my son in the back seat of his vehicle and brought him
to the emergency room of Mercy Hospital.
3. Upon examination of my son, it was determined that he had no motor
movement from the navel down to his legs. An MRI of his whole spine was done
which revealed that his spinal cord is almost cut in half at the level of T10 except
for a thin threadlike attachment.
4. Dr. House, a spine surgeon, advised immediate surgery to stabilize the
spine. The risk of the procedure were discussed with us. The risks include but are
not limited to:
a. Reaction to anesthesia or other drugs.
b. Bleeding.
c. Infection.
d. Blood clots, in the legs or lungs.
e. Heart attack.
f. Stroke.
g. Recurrent disc herniation.
h. Further nerve damage, which can result in weakness, paralysis,
pain, sexual dysfunction, or loss of bowel or bladder control.
5. After the surgery, my son was brought back to the ICU for close
monitoring. Post-operative instructions include:
a. Regular turning every 2 hours to prevent the development of
bedsores
b. Antibiotic treatment to prevent infection
c. Daily rehabilitation therapy to prevent muscle atrophy
d. Pain medication for pain control
6. All the above instructions were done except for the regular turning every 2
hours and the rehabilitation. There were times that I would beg the nurses not to
move my son because he is in so much pain doing so.
7. Three days after the surgery, the ICU nurse noted a reddening of the skin
in the buttocks. This was the beginning of the bed sore. We were referred to Wound
Care Management.
8. Two days later, my son was cleared to leave the ICU and transfer to a
regular room. The same turning and rehabilitation instructions were ordered to be
continued while in the regular room.
9. Upon arrival to the room, the nurse in charge noticed a deep bed sore on
his buttocks. We were advised to have Wound Care examine and treat the bedsore.
10. Wound Care visited my son only every other day, to treat and change the
dressing on the bedsore.
11. When asked, the Wound Care team would say that the bedsore was
slowly healing.
12. Treatment for my son continued for 4 more weeks during which, the
turning and rehabilitation could not be done regularly because of the pain.
13. Before being discharged, my son had diarrhea which soaked the dressing
on his bedsore causing it to fall off. I panicked because of how deep the sore was.
14. I refused to have my son discharged and asked the nurses to call his
attending physician/pediatrician, Dr. Love. The attending physician referred the
patient to a general surgeon, Dr. Grey.
15. Dr. Grey, upon seeing the wounds claimed that the bedsore is caused by
poor nursing care.
16. Because of the bedsore, my son had to stay for 4 more weeks at the
hospital for treatment. Upon discharged, the outstanding hospital bill was Php
1.7M.
17. I believe that my sons spine surgery with Dr. House did not go well
because of the severe pain he felt after the operation which hindered the regular
turning and rehabilitation. Also, Dr. Love, the attending physician/pediatrician, and
the nurses were negligent and unable to prevent the worsening of my sons
bedsore. Had these medical personnel been more attentive to my sons needs, he
would not have been in severe pain and he would not have had deep bedsores.
Such negligence caused by Dr. House, Dr. Love, the hospital and their staff for
Reckless Imprudence resulting in Serious Physical Injury.
18. To attest to the truthfulness of the foregoing, I, Clara Bueno,
complainant, attaches my signature below.
______________________
Clara Bueno
Complainant
____________________________________________________
SUBSCRIBED AND SWORN to before me, in the city of Taguig, this 22nd day
of December, 2017, the affiant exhibiting to me his Passport issued by Department
of Foreign Affairs Manila on 15th of April 2012 at Roxas Blvd, Manila.
______________________
Atty. Jon Snow
