G.R. No. 222740 - St. Luke's College of Medicine-William H. Quasha Memorial Foundation vs. Spouses Perez

In 2006, the Commission on Higher Education issued Memorandum Order No. 10, requiring medical students to undergo rotating clinical clerkships in their fourth year.
St. Luke’s College of Medicine (St. Luke’s) entered into a Memorandum of Intent with the Municipality of Cabiao, Nueva Ecija, for the construction of a community clinic. The clinic had a six-bed medical facility on the ground floor and residential space for medical staff on the second floor.

In February 2010, four 4th year medical students from St. Luke’s, including the daughters of respondents Spouses Perez and Spouses Quintos, were assigned to complete a four-week clerkship at the Cabiao clinic. They stayed on the second floor of the clinic.
On February 8, 2010, after their shift, the students engaged in routine activities including jogging and buying beverages, with some limited alcohol consumption admitted by one survivor, Miguel Rafael Ramos.
In the early hours of February 9, 2010, a fire broke out in the clinic. Ramos woke to Murillo shouting about the fire, attempted to extinguish it with a pail of water, and helped others by pouring water on them. Thick smoke filled the premises, and they shouted for help. Ramos was rescued through a window but suffered smoke inhalation and near loss of consciousness.

The fire resulted in the deaths of the female medical students, including the daughters of respondents, from smoke inhalation and asphyxia.
St. Luke’s compensated the parents of the deceased students Php 300,000 each from insurance proceeds.

The Bureau of Fire Protection (BFP) issued a Certification declaring the fire purely accidental due to unattended cooking. The BFP found no evidence of intentional or malicious acts.
Respondents doubted the BFP findings, held meetings with St. Luke’s officials and local government representatives, who claimed the fire was caused by the gas burner left on and noted alcohol consumption by the victims. Respondents rejected these explanations, suspecting a cover-up.
The National Bureau of Investigation (NBI) investigated and, in a Resolution, concluded that the building violated Republic Act No. 9514 (Revised Fire Code of the Philippines), fire safety measures were lacking, and that the fire was caused by faulty electrical wiring. The NBI found St. Luke’s negligent, describing the clinic as a "virtual fire/death trap."
The NBI detailed several deficiencies in the Cabiao Community Clinic: absence of fire exits, alarms, extinguishers, emergency lighting; improper and outdated electrical installation prone to short circuits; iron grill bars on windows with no fire escape; lack of proper fire safety permits; and dereliction of duties by the local BFP.

Respondents filed a Complaint for damages against St. Luke’s and its officials, alleging negligence causing the deaths of their daughters, asserting that St. Luke’s had a duty, under the enrollment contract as an educational institution, to ensure the safety of the students while performing required school activities.
The Regional Trial Court (RTC) dismissed the complaint for lack of merit, reasoning that the clinic was not a fire trap, noting two fire exits existed and that the Municipality of Cabiao, as owner of the clinic, should have been impleaded. The RTC declined to consider the NBI report as it was supposedly not presented.
On appeal, the Court of Appeals (CA) reversed and remanded the case, ruling:

The Municipality of Cabiao was not an indispensable party since the claim stemmed from the enrollment contract between St. Luke’s and the students.
The safety of the students was within St. Luke’s control and responsibility, recognizing that schooling institutions have a “built-in” obligation to provide a safe learning environment.
St. Luke’s failed to inspect the premises for fire safety, disregarded safety permits, and house students in a place with inadequate fire exits and hazardous conditions despite foreseeability of risks.
The iron grills served security from intrusion but blocked emergency egress, further evidencing negligence.

St. Luke’s filed a petition for review on certiorari alleging reversible errors by the CA in:

Holding the Municipality of Cabiao was not indispensable.
Disregarding the BFP’s finding that fire was accidental due to unattended cooking.
Finding St. Luke’s negligent.

Whether the Municipality of Cabiao is an indispensable party to the complaint for damages.
Whether the Bureau of Fire Protection’s certification that the fire was accidental and caused by unattended cooking should be given dispositive weight.
Whether St. Luke’s College of Medicine and its officials were negligent in their duty to ensure the safety of their students during the clerkship program.