Case Digest (G.R. No. L-33722)
Facts:
In 1963 at the Gabaldon Primary School in Tayug, Pangasinan, private respondent Mauro Soriano served as principal and Edgardo Aquino as teacher. After World War II remnants of a school shop left heavy one-ton concrete blocks scattered on school grounds. Another teacher began burying these hazards in 1962, but by October 1963 some remained exposed. On October 7, 1963, Aquino enlisted eighteen male pupils aged ten to eleven to dig a hole beside one such block, intending to bury it. The digging remained unfinished; the next day he summoned four of them—Reynaldo Alonso, Francisco Alcantara, Ismael Abaga, and Novelito Ylarde—to resume excavating. When the pit reached a depth of 1.4 meters, Aquino briefly left the children leveling loose soil around the open excavation to fetch rope, warning them “not to touch the stone.” Left unsupervised, three boys jumped into the pit and Abaga leaped onto the concrete block, triggering its slide that crushed Ylarde against the pit wall. Ylarde susCase Digest (G.R. No. L-33722)
Facts:
- School Environment and Initial Efforts
- In 1963, Gabaldon Primary School in Tayug, Pangasinan was headed by Principal Mauro Soriano; Edgardo Aquino was a teacher there.
- The school grounds were littered with one-ton concrete blocks, remnants of a shop destroyed in World War II; fellow‐teacher Sergio Bañez had begun burying them in 1962.
- The Excavation Project and Accident
- On October 7, 1963, Aquino ordered eighteen male pupils (ages 10–11) to dig beside one of the blocks to bury it; the work went unfinished that day.
- The next afternoon, four of the original pupils—Reynaldo Alonso, Francisco Alcantara, Ismael Abaga, and Novelito Ylarde—resumed digging until the hole was about 1.40 meters deep. Aquino then continued excavating inside the pit while the children removed loose soil.
- When the hole reached the required depth, Aquino and the pupils exited. Aquino instructed the children to level the soil around the hole, warned them “not to touch the stone,” and left to borrow rope from Bañez, some 30 meters away.
- Left unsupervised, three pupils jumped into the pit; Abaga jumped on the block, causing it to slide and trap Ylarde against the pit wall. Alonso and Alcantara escaped; Ylarde sustained crushing injuries (bladder rupture, pelvic fracture, extensive contusions) and died three days later.
- Procedural History
- Petitioners (Ylarde’s parents) sued Aquino under Civil Code Article 2176 (quasi‐delict) and Soriano under Article 2180 (liability of teachers/heads for pupils’ torts).
- The Court of First Instance dismissed the complaint, finding (a) the digging formed part of “Work Education,” (b) Aquino exercised utmost diligence, and (c) Ylarde’s own recklessness caused the accident.
- The Court of Appeals affirmed. Petitioners then elevated the case to the Supreme Court via petition for certiorari.
Issues:
- Whether Principal Soriano is liable under Civil Code Article 2180 for damages caused by his pupil’s death.
- Whether Teacher Aquino is liable under Article 2176 (fault or negligence) or Article 2180 (liability of teachers) for the death of pupil Ylarde.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)