COMPLAINT AFFIDAVIT

I, Clara Bueno, Filipino, of legal age, married, a resident of 2044 Roxas Blvd., Manila, having been sworn in
accordance with law, hereby depose and say that:
1. On 11 September 2014 at around 6AM, my son Eduardo Bueno was brought to the
emergency room of Mercy Hospital because of a vehicular accident along SLEX. He was brought by Dr.
Doctor who saw the accident and transported Eduardo in the back of his vehicle.
2. Upon examination of EB, it was determined that he had no sensation or motor movement
from the navel down to his legs. That is, he was half paralyzed. An MRI of his whole spine was done which
revealed that his spinal cord is almost cut in half at the level of T10 (the umbilicus or navel) except for a thin
threadlike attachment. Any unnecessary movement could cut this remaining attachment and completely sever
the spinal cord.
3. Eduardo was referred to Dr. House, a spine surgeon who advised immediate surgery to
stabilize the spine.
4. After the surgery, Eduardo was kept in the ICU. There, he would receive antibiotic
treatment and pain medications.
5. Dr. House also instructed the nurses to turn my son every 2 hours and to give rehabilitation
therapy.
6. I asked the nurses not to move my son, as he was still in extreme pain with every movement.
And he would also wake up when they try to turn him while he slept.
7. Three days after surgery, the ICU nurse noted a reddening of the skin in the buttocks, and
noted that it was a beginning bedsore. She referred me to the Wound Care Management to prevent the
worsening of the bedsore, to which I refused as it was an additional cost.
8. Five days later, my son was cleared to transfer to a regular room. But upon arrival, the nurse
noted a deep bed sore on his buttocks. I then agreed to have Wound Care examine and treat the bedsore.
9. Wound Care visited my son every other day to treat and change the dressing on the bed
sore. When I asked, the Wound Care team said that the bedsore was slowly healing.
10. Treatment for my son continued for 4 more weeks until he was fit for discharge. During the
4 weeks, the turning and rehabilitation schedules were not following regularly because of the pain.
11. When he was about to be discharged, my son had an episode of diarrhea which caused the
dressing on his bedsore to fall off. There I first saw the wound and how bad it was.
12. I asked Dr. Love, Eduardo’s attending physician for help. He referred us to Dr. Grey, a
general surgeon.
13. Upon seeing the wound, Dr. Grey claimed that the bedsore was caused by poor nursing care.
14. Because of the bedsore, my son had to stay 4 more weeks at the hospital for treatment.
Upon discharge, the outstanding hospital bill was PHP 1.7M.
15. I believe that my son’s post-operation instructions were mishandled by Dr. House, Dr. Love,
the nurses, and the hospital. Had my son been taken cared of properly, he would not have developed a
bedsore and he would not incur additional expenses. Such negligence caused by Dr. House, Dr. Love, the
hospital, and their staff prompted me to file this action for Medical Malpractice.

IN WITNESS WHEREOF, I have hereunto affixed my signature this 27th day of October, 2017 in
Manila, Philippines.