G.R. No. 157906 - Capili vs. Spouses Cardana

Petitioner Joaquinita P. Capili, the principal of San Roque Elementary School, was responsible for the maintenance and safety of the school premises.
Jasmin D. CardaAa, a 12-year-old Grade 6 student of the school, died instantly after a branch from a dead and rotting caimito tree fell on her as she was walking along the perimeter fence on February 1, 1993.

On December 15, 1992, before the incident, a resident of the barangay, Eufronio Lerios, reportedly alerted Capili to the potential danger posed by the tree.
Lerios informed the petitioner regarding the tree’s hazardous condition and even mentioned an offer to buy it; however, the petitioner contended that Lerios had merely proposed the offer without indicating the tree’s dangerous state.
The petitioner asserted that during a meeting with her teachers on the same day, she discussed Lerios’ proposal and assigned teacher Remedios PalaAa to negotiate the sale and presumably handle the tree’s disposition.

The parents of Jasmin, Dominador and Rosalita CardaAa, filed a case for damages before the Regional Trial Court of Palo, Leyte, alleging that the petitioner’s negligence resulted in their daughter’s death.
The trial court, in its Decision dated February 5, 1996, dismissed the complaint for failure of the respondents to establish the petitioner’s negligence.
On appeal, the Court of Appeals reversed the dismissal and declared petitioner negligent, holding her liable for Jasmin CardaAa’s death and ordering her to pay specified amounts for:

The petitioner’s motion for reconsideration of the negative finding was denied.
Petitioner elevated the case to a petition for review, contesting both the negligence finding under Article 2206 of the Civil Code and the denial of her motion for reconsideration.
Respondents maintained that the appellate decision should be affirmed without disturbance.

Whether the Court of Appeals erred in finding that the petitioner was negligent and, as a result, liable for damages under Article 2206 of the Civil Code in connection with the death of Jasmin D. CardaAa.

Petitioner argued that she had no actual knowledge of the tree’s rotten condition because the only information she received was an offer from Lerios, which did not indicate imminent danger.
She maintained that assigning the matter to her subordinate, Remedios PalaAa, fulfilled her supervisory obligations.

Whether the Court of Appeals erred in denying the petitioner’s motion for reconsideration concerning her negligence and the consequent award of damages.

Petitioner questioned the extent of her liability and the appropriateness of the damages, particularly the award of moral damages.
Respondents countered by asserting that the petitioner, as the principal, had a duty to exercise prudence and vigilance in ensuring the safety of the school premises, which she failed to do.

Petitioner contended that moral damages should not be granted as there was no fraud or bad faith on her part.
Respondents argued that reasonable care was not exercised and that the petitioner’s neglect was sufficient to warrant a moral damages award, although this award was later deleted by the final decision.