Title
Capili vs. Spouses Cardana
Case
G.R. No. 157906
Decision Date
Nov 2, 2006
A 12-year-old student died when a rotting tree branch fell on her at school. The principal, warned earlier about the danger, was found negligent for failing to ensure safety, leading to liability for damages.
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Case Digest (G.R. No. 157906)

Facts:

  1. Incident Overview: On February 1, 1993, Jasmin Cardaña, a 12-year-old Grade 6 student at San Roque Elementary School, was walking along the perimeter fence of the school when a branch of a caimito tree within the school premises fell on her, causing her instantaneous death.

  2. Prior Warning: As early as December 15, 1992, Eufronio Lerios, a barangay resident, reported to Joaquinita Capili, the school principal, about the potential danger posed by the tree. Lerios pointed out the tree, which was near the principal's office.

  3. Petitioner’s Defense: Capili denied knowing the tree was dead and rotting. She claimed Lerios only offered to buy the tree for firewood. She also stated that she had assigned Remedios Palaña, another teacher, to negotiate the sale of the tree.

  4. Trial Court Decision: The Regional Trial Court of Palo, Leyte, dismissed the complaint filed by Jasmin’s parents, Dominador and Rosalita Cardaña, for failure to prove negligence on Capili’s part.

  5. Court of Appeals Decision: The appellate court reversed the trial court’s decision, holding Capili liable for negligence and ordering her to pay damages to the Cardañas.

Issue:

  1. Primary Issue: Whether petitioner Joaquinita Capili was negligent and liable for the death of Jasmin Cardaña under Article 2206 of the Civil Code.

  2. Subsidiary Issues:

    • Whether the Court of Appeals erred in finding Capili negligent and ordering her to pay damages.
    • Whether the Court of Appeals erred in denying Capili’s motion for reconsideration.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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