Case Digest (G.R. No. L-29025)
Facts:
Spouses Moises P. Palisoc and Brigida P. Palisoc v. Antonio C. Brillantes, et al., G.R. No. L-29025. October 04, 1971, the Supreme Court En Banc, Teehankee, J., writing for the Court.The plaintiffs-appellants, Spouses Moises P. Palisoc and Brigida P. Palisoc, sued for damages as heirs of their sixteen-year-old son, Dominador Palisoc, who died on March 10, 1966 after a physical altercation in the laboratory room of the Manila Technical Institute (M.I.T.). Defendants named in the complaint were Antonio C. Brillantes (alleged registered owner/head and at the time a member of the board of directors), Teodosio V. Valenton (president of the Institute), Santiago M. Quibulue (instructor of the class), and Virgilio L. Daffon (a fellow student and the assailant).
The trial court found, crediting the lone eyewitness Desiderio Cruz, that Daffon struck Dominador repeatedly during a recess, causing him to stumble, fall, and suffer internal injuries (fractured ribs, contusion of pancreas and stomach, subarachnoid hemorrhage) that caused death. The trial court held Daffon liable under Article 2176 (quasidelict) and awarded the plaintiffs monetary damages (P6,000 for death, plus other items totaling additional sums), and dismissed the defendants’ counterclaim. However, the trial court absolved the school officials (Valenton, Quibulue and Brillantes) from liability, interpreting Article 2180 of the Civil Code to apply only where the pupil “lives and boards” with the teacher so that custody supersedes parental control; the court relied on dicta in Mercado v. Court of Appeals and Exconde v. Capuno.
Plaintiffs appealed, contending that under Article 2180 the school officials (as heads/teachers of an arts-and-trades establishment) should have been held jointly and several...(Subscriber-Only)
Issues:
- Are the trial court’s factual findings and credibility determinations binding on this Court in the present appeal?
- Under Article 2180 of the Civil Code, may teachers or heads of establishments of arts and trades be held liable for damages caused by their pupils or students while the latter are attending school (including recess), even if the pupils do not live and board with the teacher?
- Should the award for death be increased to P12,000 and should exemplary damages, legal interes...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)