Case Digest (G.R. No. 84698) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Philippine School of Business Administration v. Court of Appeals (G.R. No. 84698, February 4, 1992), the parents of third-year commerce student Carlitos Bautista filed a damage suit in the Regional Trial Court of Manila, Branch 47, presided by Judge Regina Ordonez-Benitez, after Carlitos was fatally stabbed on August 30, 1985, while on the second floor of the Philippine School of Business Administration (PSBA). The petitioners—PSBA and its officers Juan D. Lim (President), Benjamin P. Paulino (Vice-President), Antonio M. Magtalas (Treasurer), Col. Pedro Sacro (Chief of Security), and Lt. M. Soriano (Assistant Chief of Security, who later resigned)—were charged with negligence for failing to provide adequate security precautions against outsiders who perpetrated the attack. The petitioners moved to dismiss, arguing no cause of action under Article 2180 of the Civil Code since the assailants were not students. The RTC denied the motion on December 8, 1987, and also denied recon Case Digest (G.R. No. 84698) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties Involved
- Private Respondents (Plaintiffs)
- Seguna R. Bautista and Arsenia D. Bautista – parents of the deceased student.
- Petitioners (Defendants)
- Philippine School of Business Administration (PSBA)
- Juan D. Lim – President
- Benjamin P. Paulino – Vice-President
- Antonio M. Magtalas – Treasurer/Cashier
- Col. Pedro Sacro – Chief of Security
- Lt. M. Soriano – Assistant Chief of Security (resigned during proceedings)
- Stabbing Incident
- Date and Location
- 30 August 1985, PSBA second-floor premises, Manila.
- Victim and Assailants
- Victim: Carlitos Bautista, third-year commerce student.
- Assailants: Outsiders, not members of PSBA’s academic community.
- Procedural History
- Trial Court (RTC, Manila, Branch 47)
- Complaint filed for damages against PSBA and its officers, alleging negligence and lack of security.
- Motion to dismiss under Article 2180, Civil Code – denied by order dated 8 December 1987; reconsideration denied on 25 January 1988.
- Court of Appeals
- Petitioners’ appeal – decision promulgated 10 June 1988, affirmed RTC orders.
- Motion for reconsideration – denied on 22 August 1988.
- Supreme Court
- Petition for review under G.R. No. 84698.
Issues:
- Applicability of Article 2180, Civil Code (in loco parentis liability) when damage is caused by non-students.
- Whether PSBA’s contractual relation with the student gives rise to an obligation to provide security and can ground liability.
- The interplay between quasi-delict (tort) under Article 2176 and contractual obligations in the context of school-student relations.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)