Case Digest (G.R. No. 186339) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Spouses Moises P. Palisoc and Brigida P. Palisoc v. Antonio C. Brillantes et al. (G.R. No. L-29025, decided October 4, 1971 under the 1935 Constitution), the parents of sixteen-year-old Dominador Palisoc, a student of automotive mechanics at the Manila Technical Institute (M.I.T.), sued for damages after their son’s death on March 10, 1966. According to an eyewitness, fellow student Virgilio L. Daffon taunted Dominador, who lightly slapped him; Daffon then struck Dominador with powerful fist blows in the face and stomach. Dominador stumbled over an engine block, fell unconscious, and died without regaining consciousness. A postmortem examination revealed fractured ribs, internal hemorrhages, and brain injury consistent with strong fist blows. The Court of First Instance of Manila found Daffon liable for a quasidelict under Article 2176 of the Civil Code, awarded P6,000 for death indemnity plus additional expenses, and absolved three school officials—Antonio C. Brillantes (boa Case Digest (G.R. No. 186339) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and background
- Plaintiffs-appellants: Spouses Moises P. Palisoc and Brigida P. Palisoc, parents of Dominador Palisoc, 16-year-old automotive mechanics student at Manila Technical Institute (M.I.T.).
- Defendants-appellees:
- Virgilio L. Daffon, fellow student and assailant.
- Santiago M. Quibulue, class instructor.
- Teodosio V. Valenton, president of M.I.T.
- Antonio C. Brillantes, member of the Board of Directors and former proprietor.
- Incident and injuries
- On March 10, 1966, between 2 and 3 PM, during recess in the ground-floor laboratory, Daffon and Desiderio Cruz operated machinery while Palisoc observed.
- Daffon taunted Palisoc, who slapped him; Daffon retaliated with forceful blows to Palisoc’s face and stomach, chasing him until Palisoc stumbled on an engine block, fell unconscious, and later died.
- Trial court findings and judgment
- Findings: Based on the lone eyewitness, Desiderio Cruz, and autopsy (fractured ribs, pancreatic contusion, subarachnoid hemorrhage), Daffon’s blows caused fatal internal injuries.
- Liability: Daffon held liable under Article 2176 (quasi-delict); school officials absolved under Article 2180, construed to require boarding “in custody.”
- Award: Daffon ordered to pay P6,000 (death indemnity), P3,375 (expenses), P5,000 (moral damages), P10,000 (loss of earning power), P2,000 (attorney’s fee); costs asserted; counterclaim dismissed; other defendants absolved.
Issues:
- Whether instructors and school heads (Valenton and Quibulue) are liable under Article 2180, Civil Code, for torts of students during school custody.
- Whether death indemnity should be increased from P6,000 to P12,000 under People v. Pantoja and Article 2206, Civil Code.
- Whether exemplary damages, legal interest, or increased attorney’s fees are warranted.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)