G.R. No. 82465 - St. Francis High School vs. Court of Appeals

Petitioners: St. Francis High School represented by spouses Fernando Nantes and Rosario Lacandula, and Benjamin Illumin (principal), plus teachers Tirso de Chavez, Luisito Vinas, Connie Arquio, Nida Aragones, Yoly Jaro, and Patria Cadiz.
Respondents: Spouses Dr. Romulo Castillo and Lilia Cadiz Castillo, parents of the victim Ferdinand Castillo.

Ferdinand Castillo, a 13-year-old freshman student of Section I-C, wished to join a school picnic held by Classes I-B and I-C at Talaan Beach, Sariaya, Quezon.
Respondents, due to short notice, did not allow full participation but permitted Ferdinand to bring food to teachers and instructed him to return afterward.
Ferdinand was persuaded by teachers to join the picnic fully and entered the water with other students.
During the picnic, a female teacher began to drown; several students, including Ferdinand, attempted rescue. Ferdinand drowned in the process.
Ferdinand’s body was recovered but resuscitation attempts failed; he was declared dead at Mt. Carmel General Hospital.

Respondents filed a complaint for damages against the school, principal, and the involved teachers.
The trial court found teachers Connie Arquio, Tirso de Chavez, Luisito Vinas, Yoly Jaro, Nida Aragones, and Patria Cadiz negligent for failing to exercise proper diligence.
The court ordered these teachers jointly and severally liable for actual damages (P30,000), moral damages (P20,000), attorney's fees (P15,000), and costs.
The court absolved the school, Benjamin Illumin, and Aurora Cadorna, ruling insufficient evidence of their liability or school sponsorship of the picnic.

Respondents appealed to include the school and principal as liable parties, alleging their failure to control or supervise the picnic.
The Court of Appeals held that:

The picnic, even if not school-sanctioned, was supervised by school teachers, including the class adviser and others invited.
There was acquiescence by the principal who knew about the picnic but did not prohibit it nor impose safety measures.
Thus, under Articles 2176 and 2180 of the Civil Code, the school and principal are jointly and severally liable with the teachers.
Exemplary damages of P20,000 were added to the previously awarded actual and moral damages, and attorney’s fees.
Defendants Yoly Jaro and Nida Aragones were absolved due to their absence during the drowning and their justified delay due to other official duties.

Petitioners likewise appealed the finding of negligence against the teachers and the dismissal of their counterclaim.

The Supreme Court took cognizance of the petition for review and required memoranda from parties.
The petitioners argued:

Their negligence was not proven; they exercised the diligence of good fathers of families.
The picnic was purely private and not a school activity; thus, no liability under Article 2180.
Respondents consented to the picnic by allowing the son to participate by giving him money.
The teachers present made all possible efforts to save Ferdinand and safety measures were observed.

Petitioners could not be held liable as the drowning occurred during a private affair, with the teachers not performing assigned tasks or acting in the scope of their employment.
Article 2180 requires the act or omission to have occurred within the performance of assigned tasks for an employer’s liability to attach.
Petitioners exercised due diligence: teachers invited swimming instructors; first aid and resuscitation were promptly applied.
The award of moral and exemplary damages was unwarranted given the lack of negligence.

The Supreme Court thus set aside the Court of Appeals decision insofar as petitioners’ negligence and liability were concerned but affirmed dismissal of petitioners’ counterclaim.

Petitioners-teachers (except Aragones and Jaro) were negligent for failing to properly supervise children, neglecting to check water depth, and male teachers absented themselves during the critical time allegedly indulging in drinking.
Negligence was established by their failure to prevent harm (diligence before the fact).
The participation of multiple teachers in organizing and supervising constitutes school authority, rendering the school and its principal liable under Articles 2176 and 2180.
Knowledge by the principal and failure to act constituted implied consent and acquiescence.
Moral and exemplary damages were justified due to negligence causing the death.

The dissent emphasized the special nature of schools’ duties toward minors and the need for accountability.

Whether there was negligence attributable to the defendants (school, principal, and teachers) warranting damages to respondents.
Whether Article 2180 in relation to Article 2176 of the Civil Code is applicable, imposing liability on the school and its principal for the actions or omissions of the teachers.
Whether the award of moral and exemplary damages was proper under the circumstances.