Case Summary (G.R. No. L-47745)
Factual Background
Alfredo Amadora returned to campus to complete or submit a physics requirement following the formal close of his last semester. While on school premises, he was shot and fatally wounded by fellow student Pablito Daffon. Daffon was subsequently criminally convicted of homicide through reckless imprudence.
Trial and Appellate Proceedings
– Civil claim for damages filed under Civil Code Article 2180 against the school, its officials, and the gun-owner’s parents.
– Court of First Instance (Cebu) held the school and its officials solidarily liable and awarded ₱294,984.00 for death compensation, loss of earning capacity, moral and exemplary damages, attorney’s fees, etc.
– On appeal, the Court of Appeals reversed, absolving all defendants on grounds that Article 2180 did not apply to an academic institution, no custody existed after semester’s end, firearm identity was unproven, and due diligence had been exercised.
Issues Presented
- Does Civil Code Article 2180 (liability of teachers or heads of establishments for torts of pupils or apprentices “while in their custody”) extend to academic schools and to periods outside formal class hours or semesters?
- Were the school’s officials—and, derivatively, the school itself—liable for Alfredo’s death, given the alleged negligence of returning a confiscated pistol?
Precedent Analysis (Article 2180)
– Exconde v. Capuno (1957) and Mercado v. Court of Appeals (1960): held non-technical schools not covered; “custody” narrowly construed as boarding or live-in supervision; dicta questioned broader teacher liability.
– Palisoc v. Brillantes (1971): extended “custody” to protective and supervisory custody during attendance, including recess; recognized that academic versus technical distinction would require further case law.
Interpretation of Article 2180
– Applies equally to academic and non-academic schools.
– General rule: teachers are liable for torts committed by pupils “while in their custody” (i.e., under their supervisory influence on school premises for legitimate student objectives).
– Exception: in establishments of arts and trades, only the head is liable (historically due to in-depth master-apprentice relationship).
– Custody extends beyond formal class periods to include legitimate campus activities before or after the semester, so long as the student is on premises under school discipline.
Scope of Liability and Defenses
– Liability attaches to the teacher-in-charge, not necessarily to school administrators or the institution itself.
– “Teacher-in-charge” need not be physically present at the incident; custody is about supervisory influence, not immediate control.
– Defendants may exonerate themselves by proving they exercised the diligence of a good father of a family (due diligence defense).
Application to This Case
– Alfredo was within the school’s custody at the time of the shooting, even though classes had formally ended, because he was
Case Syllabus (G.R. No. L-47745)
Facts
- Alfredo Amadora, a 17-year-old prospective high school graduate, was shot dead on April 13, 1972 in the auditorium of Colegio de San Jose-Recoletos by fellow student Pablito Daffon.
- Daffon was subsequently convicted of homicide through reckless imprudence.
- Alfredo had gone to school allegedly to complete a physics experiment or submit his final report, shortly before commencement exercises.
- On April 7, 1972, Dean of Boys Sergio Damaso, Jr. had confiscated an unlicensed pistol from Jose Gumban but later returned it without reporting the matter or imposing discipline.
Procedural History
- Civil complaint under Article 2180, Civil Code, was filed by Alfredo’s parents against the school, its officials (rector, principal, dean of boys, physics teacher), Daffon and two other students (later dropped).
- Trial Court (Cebu CFI) held the school and its officials jointly liable for ₱294,984.00 in damages (death compensation, loss of earning capacity, funeral expenses, moral and exemplary damages, attorney’s fees).
- On appeal, the Court of Appeals reversed, absolving all defendants on grounds that Article 2180 did not apply to academic institutions, custody had ended with the semester, gun identity unclear, and defendants exercised due diligence.
- Petitioners sought certiorari under Rule 45 before the Supreme Court.
Issue
- Whether Article 2180 of the Civil Code (liability of teachers or heads of establishments of arts and trades for torts of pupils or apprentices in their custody) applies to an academic institution and its teachers.
- When, for purposes of Article 2180, a pupil or student is deemed “in the custody” of the school authorities.
- Whether any school official or teacher was negligent in supervision or discipline, thereby incurring liability.
Statutory Provision (Article 2180, Civil Code)
- “Teachers or heads of establishments of arts and trades shall be liable for damages caused by their pupils and students or apprentices so long as they remai