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February 17, 2019

Dir. Marilyn E. Taldo


Director IV, Civil Service Commission-CAR
No. 116 Wagner Road,
Military Cut-Off. Baguio City 2600

Dear Director Marilyn E. Taldo:

I, Brenda Mendoza, attending nurse in the complaint, after


having sworn in accordance with law, hereby depose and say
that:
1. On September 1, 2018, at about 7:50 in the evening Jessie
Jay Bayucan was admitted at Baguio General Hospital as she
is about to deliver her first child;

2. I was the one who admitted Jessie Jay Bayucan and I also
attended her delivery;

3. That it was Dr. Harrison Barnes who first attended Jessie Jay
Bayucan; thereafter, Jessie Jay Bayucan was endorsed to Dr.
Pamela Juanita Santiago;

4. That Dr. Santiago, on that night, was also attending


numerous patients admitted and confined in the hospital and
that only Dr. Santiago and Dr. June Morales were only duty;
5. That the hospital’s private rooms were full and there was only
one available bed in the charity ward which was given to
Jessie Jay Bayucan;

6. That Dr. Santiago immediately attended to Jessie Jay


Bayucan who was already in the delivery room after she
assisted in the delivery of the child another patient;

7. That Dr. Santiago asked for the ultrasound of Jessie Jay


Bayucan and she learned that the baby is breech;

8. Dr. Santiago together with Dr. Shiela Padilla advised Jessie


Jay Bayucan and her husband Melford Bayucan that she
should undergo caesarian section due to the difficulty of
delivering a breached baby. She asked them to sign an
informed consent but they refused;

9. That spouses Bayucan insisted normal delivery because they


believe that she is fully capable to deliver the baby and that
the baby is healthy and because caesarian section is more
expensive than normal delivery as well as the fact that
recovery from caesarian section is longer than normal
delivery;

10. That while delivering the child, Jessie Jay had difficulty
pushing thereby causing injuries to the baby;

11. That while delivering the baby, Dr. Santiago ruled cord
loop and the baby’s head was stuck in the perenium of the
mother;
12. That Dr. Santiago had to hasten the delivery because the
baby was already in critical condition due to asphyxia or
oxygen deprivation;

13. That Dr. Santiago was able to remove the cord loop and
deliver the baby but unfortunately, the baby was already
dead.

Brenda Mendoza, RN
Affiant
February 17, 2019
123456
Valid until: November 10, 2019