Case Summary (G.R. No. 133064)
Facts of the Case
Dante Capuno, then fifteen years old and a Boy Scouts member and elementary student, negligently drove a jeep during a school parade commemorating Dr. Jose Rizal. The jeep overturned, resulting in the deaths of two passengers, including Isidoro Caperina, son of Sabina Exconde. Dante was criminally found guilty of double homicide through reckless imprudence. Sabina reserved her right to file a separate civil action for damages, which she pursued against both Dante and his father, Delfin Capuno, claiming joint and several liability for the damages due to Dante being a minor living with his father. The defendants contended that only Dante should be liable since he was not under his father’s control or custody at the time. The lower court absolved Delfin Capuno of civil liability and held only Dante liable. Sabina Exconde appealed.
Issue
Whether Delfin Capuno could be held civilly liable, jointly and severally with his son Dante, for damages resulting from the death of Isidoro Caperina caused by Dante’s negligent act when Dante was a minor living with his father.
Legal Framework
The case involves interpretation of Article 1903 of the Spanish Civil Code, which imposes civil liability on:
- Parents for damages caused by their minor children living with them;
- Teachers or directors of arts and trades for damages caused by their pupils or apprentices under their custody.
Articles 154 and 155 authorize parental authority over minor children, including the duty to support, keep, educate, instruct, and correct them moderately. This parental authority entails civil liability for damages caused by minors living with their parents, unless the parents can prove they exercised due diligence.
Court’s Analysis
The Court emphasized that Dante Capuno was a minor living with his father, Delfin Capuno, at the time of the negligent act resulting in the deaths. It reinforced that parental liability arises from the duty of care and supervision emanating from parental authority, which includes supporting, educating, and correcting the child.
The Court distinguished the provision imposing liability on “teachers or directors of arts and trades” by clarifying that it applies only to arts and trades institutions, not to academic educational institutions. Dante, being a student of an elementary school (an academic institution), and attending a parade under instruction of the City School Supervisor, does not fall under the scope of this provision. The Court noted doctrinal authority and prior jurisprudence supporting this distinction.
Therefore, the Court concluded that Delfin Capuno is liable jointly and severally with his son because at the time of the incident, Dante was a minor living with his father, which triggers the presumption of parental liability under Article 1903. The father could avoid liability only by proving the exercise of sufficient vigilance, which he failed to do.
Court’s Ruling
The Court modified the lower court’s decision, holding Delfin Capuno jointly and severally liable with his son, Dante Capuno, to pay the plaintiff damages amounting to P2,959.00, including costs of the action.
Dissenting Opinion
Justice Reyes dissented, arguing that Article 1903’s reference to “teachers or heads of establishments of arts and trades” should encompass all teachers, including those in academic institutions, because there is no substantial difference regarding their duty of supervision over pupils. He construed the phrase to mean that when a parent entrusts a minor child to the custody of competent school authorities, the liability for damages committed by the child while under such custody shifts to those authorities, not to the parent.
Justice Reyes po
...continue readingCase Syllabus (G.R. No. 133064)
Facts of the Case
- Dante Capuno, a minor aged fifteen (15) years, was accused and found guilty of double homicide by reckless imprudence for the death of Isidoro Caperina and Amado Ticzon on March 31, 1949.
- The incident occurred when Dante, a student and Boy Scout member, took control of a jeep during a school-sanctioned parade honoring Dr. Jose Rizal in San Pablo City, causing the vehicle to overturn and resulting in the deaths.
- Sabina Exconde, mother of one victim, Isidoro Caperina, reserved her right to file a separate civil suit for damages against the accused.
- Later, she filed suit against Delfin Capuno (father) and Dante Capuno (son) requesting P2,959.00 in damages for her son’s death.
- The lower court and the Court of Appeals held only Dante responsible for the damages, absolving Delfin Capuno based on the defense that Dante was not under Delfin’s supervision or custody at the time of the accident.
Issue on Appeal
- Whether Delfin Capuno, the father, can be held civilly liable jointly and severally with his son Dante for the damages resulting from Dante’s negligent act causing the death of Isidoro Caperina.
Legal Context and Relevant Law
- The case falls under Article 1903, paragraphs 1 and 5, of the Spanish Civil Code, which provides:
- Liability not only for personal acts but also acts of persons for whom another is responsible.
- Parents (father, or mother in case of father’s death or incapacity) are liable for damages caused by minor children living with them.
- Teachers or heads of arts and trades schools are liable for damages caused by their pupils or apprentices under their custody.
- Plaintiff argued the father’s liability arises because Dante was a minor living with him at the time of the incident, a fact undisputed.
- Defendants contended Dante was not under Delfin’s control during the school activity, thus Delfin should not be held liable.
Court’s Findings and Reasoning (Majority)
- The provision imposing liability on teachers or heads of arts and trades schools was distinguished as applicable only to institutions of arts and trades, not academic schools such as an elementary school.
- Dante was attending the parade as a student of an academic school (Balintawak Elementary School), which does not fall under the “arts and trades” category.
- Parental liability is a natural consequence of parental authority, which includes t