Title
St. Joseph's College vs. Miranda
Case
G.R. No. 182353
Decision Date
Jun 29, 2010
A grade six student suffered chemical burns during a science experiment due to inadequate supervision and safety measures. The Supreme Court held the school, its administrators, and teacher liable for negligence, affirming damages for medical expenses, emotional suffering, and litigation costs.

Case Digest (G.R. No. 157294-95)
Expanded Legal Reasoning Model

Facts:

  • Incident and parties involved
    • On November 17, 1994, at approximately 1:30 PM, inside the premises of St. Joseph's College (SJC), a class was conducting a science experiment involving the fusion of sulphur powder and iron fillings.
    • The experiment was supervised by petitioner Rosalinda Tabugo, the subject teacher and employee of SJC. The adviser of the class was Estefania Abdan.
    • During the experiment, Tabugo left the classroom without adequately securing the activity to prevent untoward incidents.
    • Respondent Jayson Miranda, a grade six pupil and assistant leader of his group, looked into a test tube holding the heated compound using a magnifying glass.
    • The test tube unexpectedly spurted out particles which hit Jayson's eye (particularly the left eye) and other students, resulting in chemical burns.
    • Jayson required surgery and ongoing medical treatment. His injuries led to considerable medical expenses and distress for him and his family, including his mother having to return from abroad incurring travel expenses and loss of income.
  • The claims and counterclaims
    • Respondent filed a case for damages against petitioners on the grounds of negligence and failure to exercise proper care. He sought actual damages, moral damages, attorney’s fees, and litigation expenses.
    • Petitioners argued that Jayson was a person of sufficient age and understanding who violated explicit instructions not to look into the test tube until the heated compound had cooled.
    • Petitioners contended that Jayson's contributory negligence was the proximate cause of the injury and denied liability.
    • They claimed that medical expenses were advanced by the school upon request and that Jayson apologized to Tabugo for disregarding instructions.
    • Prior demands for payment of medical expenses from petitioners were refused, prompting the filing of the complaint.
  • Decisions of the lower courts and appeals
    • The Regional Trial Court (RTC) ruled in favor of Jayson, finding petitioners jointly and solidarily liable for damages, awarding actual damages (less reimbursement to the school), moral damages, attorney’s fees, and costs of suit.
    • The Court of Appeals (CA) affirmed the RTC decision in toto, emphasizing the petitioners’ negligence and duty of care.
    • Petitioners appealed by certiorari to the Supreme Court, arguing errors regarding the proximate cause of injury, contributory negligence, damages, attorney’s fees, and denial of their counterclaim.

Issues:

  • Whether the proximate cause of Jayson’s injury was his own negligence or the negligence of the petitioners.
  • Whether the petitioners exercised the degree of care and supervision required during the science experiment.
  • Whether contributory negligence on the part of Jayson should bar or reduce his recovery.
  • Whether the awards of actual damages, moral damages, attorney’s fees, and costs were proper.
  • Whether the petitioners’ counterclaim should have been granted.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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