Case Digest (A.M. No. RTJ-07-2052)
Facts:
On June 9, 1995, William Carpitanos and Lucia Carpitanos filed a civil action before the Regional Trial Court (Branch 6, Dipolog City) for the death of their only son, Sherwin Carpitanos, who perished on February 20, 1995 in a traffic accident while participating in an enrollment campaign organized by St. Mary’s Academy of Dipolog City. From February 13 to 20, 1995, the Academy’s student-volunteers conducted visits to nearby public schools to solicit enrollments for the 1995–1996 school year. Sherwin rode in a Mitsubishi jeep owned by Vivencio Villanueva and driven at the time by 15-year-old student James Daniel II. The jeep allegedly “turned turtle” due to a detached steering wheel guide, causing Sherwin’s fatal injuries. On February 20, 1997, the trial court held St. Mary’s Academy principally liable under Articles 218 and 219 of the Family Code, awarding a total of ₱600,000 plus costs, with subsidiary liability on James Daniel Sr. and Guada Daniel. The Academy appealed to theCase Digest (A.M. No. RTJ-07-2052)
Facts:
- Filing of Complaint and RTC Decision
- On June 9, 1995, spouses William and Lucia Carpitanos filed a civil action for damages before the Regional Trial Court (RTC) of Dipolog City, Branch 6, against James Daniel II, his parents (James Daniel Sr. and Guada Daniel), the vehicle owner Vivencio Villanueva, and St. Mary’s Academy, for the death of their son Sherwin Carpitanos.
- On February 20, 1997, the RTC rendered judgment ordering St. Mary’s Academy to pay indemnity (₱50,000), actual damages (₱40,000), moral damages (₱500,000), attorney’s fees (₱10,000) and costs, with subsidiary liability on the Daniels in case of the school’s insolvency; James Daniel II and Villanueva were absolved.
- Enrollment Drive and Fatal Accident
- From February 13 to 20, 1995, St. Mary’s Academy conducted an off-campus enrollment campaign in Dipolog City and environs. As part of the campaign, student–volunteers, including Sherwin Carpitanos, visited public schools to solicit enrollees.
- On the day of the accident, Sherwin rode in a Mitsubishi jeep owned by Vivencio Villanueva and driven by 15-year-old James Daniel II. The jeep “turned turtle” when its steering-wheel guide detached. Sherwin died from injuries sustained.
Issues:
- Whether the Court of Appeals erred in holding St. Mary’s Academy liable for the death of Sherwin Carpitanos under Articles 218 and 219 of the Family Code.
- Whether the Court of Appeals erred in affirming the award of ₱500,000 moral damages against St. Mary’s Academy.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)