G.R. No. L-41314 - Union Carbide Labor Union vs. Union Carbide Philippines, Inc.

In 2007, Rhys Palaganas (Rhys) was enrolled in Mother Goose Special School System, Inc. (Mother Goose School) in Dagupan City, Pangasinan, with classmates Noel Fernandez (Noel) and Mark Dy (Mark).
On January 19, 2007, Noel lost his mechanical pencil during Music class; Rhys found and took it home. Rhys used the pencil without initially returning it.
On January 26, 2007, during Computer class, after Noel requested his pencil’s return and Rhys denied having it, Mark punched Rhys’s left arm six times and Noel punched Rhys five times. The teacher-in-charge, Mr. Gerald Gomez (Gomez), was absent in the classroom, being in the comfort room at the time.

On January 29, 2007, Rhys reported to his Hekasi teacher, Mr. Mark Anthony Gallardo, that he had been punched, but no action was taken.
On February 1, 2007, a classmate notified the class adviser, Teacher Cecil, who confirmed the punches after querying Noel and Mark.
That afternoon, Gloria Fernandez (Noel’s mother) called Rhys’s mother, Villa Palaganas, to apologize. Rhys’s parents, Villa and Samuel Palaganas (Samuel), learned of the incident only then.

Samuel had Rhys undergo medical examination. On February 2, 2007, the Palaganas went to the school to complain but were ignored.
Samuel sent two letters requesting an investigation (February 7 and 26, 2007) to the school principal, Mrs. Julia Palaroan (Palaroan).
The school’s investigation inaccurately reported the date, number of punches, and disciplinary actions—downplaying the incident as mere “teasing.” Mark Dy was cleared despite admission of multiple punches, and no penalties were imposed on him.
Samuel requested a reinvestigation, which was conducted on March 5, 2007, and yielded the same conclusion of “teasing” with no sanctions for Mark.

Samuel and Villa filed a Complaint for Damages against the offenders’ fathers, Mother Goose School (represented by its Director for Academic Affairs, Dr. Aurora Samson-Reyna), and school personnel (Palaroan, Gomez, and Gallardo), alleging negligence by the school and its personnel.
The fathers of Noel and Mark denied liability, claiming the boys were just playing.

The RTC, in its March 17, 2017 Decision, held Mother Goose School and Mr. Gomez solidarily liable for negligence, reasoning that the school was exercising parental authority and failed in its duty to protect Rhys on school premises during class hours.
Judgment awarded PHP 500,000.00 as moral damages, PHP 200,000.00 as exemplary damages, and PHP 150,000.00 as attorney’s fees.
A partial motion for reconsideration was denied on January 3, 2019. Mother Goose School and Gomez appealed to the Court of Appeals (CA).

In its May 23, 2023 Decision, the CA affirmed the RTC’s ruling with modifications.
The CA exonerated Mr. Gomez since he was not negligent being absent at the time with no substitute teacher.
The CA held Mother Goose School directly liable for negligence in handling the “bullying” incident but reduced moral damages to PHP 300,000.00.
The appeal was partly granted to the extent of dismissing the complaint against Gomez and reducing damages; affirmed in all other respects.

Mother Goose School elevated the case via Petition for Review on Certiorari to the Supreme Court assailing the CA Decision.

Whether Mother Goose Special School System, Inc. may be held liable for negligence in its handling of the punching incident among its pupils.