Case Summary (G.R. No. 239090)
Applicable Law and Constitution
Governing Constitution: 1935 Philippine Constitution (decision rendered October 4, 1971).
Civil Code provisions: Article 2176 (quasi-delict liability), Article 2180 (liability of persons for acts of those in their custody), Article 2206 (death indemnity), Article 2211 (moral damages), Article 2208 (loss of earning power), Article 2231 (exemplary damages), and Articles 349, 350, 352 (in-loco-parentis duties).
Factual Background of the Incident
On March 10, 1966, during a class recess in the laboratory room, Dominador Palisoc (16 years old) observed classmates Virgilio L. Daffon and Desiderio Cruz at work. After Daffon alleged that Palisoc was acting like a foreman, Palisoc slapped Daffon. Daffon retaliated with strong punches to Palisoc’s face and abdomen. Palisoc stumbled over an engine block, fell unconscious, and later died in hospital without regaining consciousness.
Trial Court Findings and Ruling
The trial court credited eyewitness testimony of Desiderio Cruz and the postmortem report establishing traumatic rib fractures, pancreatic and gastric contusions, intra-gastric hemorrhage, and subarachnoid hemorrhage—injuries “probably by strong fist blows.” It held Daffon liable under Article 2176 for quasi-delict. Under Article 2180, however, it absolved school officials on the ground that “custody” required proof the student lived and boarded with the institution’s teachers or heads, which was absent.
Issue on Appeal
Whether the president and instructor of a vocational-technical school are jointly and severally liable under Article 2180 for the quasi-delict committed by a student during school attendance, notwithstanding that the student does not board at the institution.
Supreme Court’s Interpretation of “Custody”
The Court held that “custody” under Article 2180 refers to the protective and supervisory authority exercised by teachers and heads of establishments over students during attendance, including recess, rather than residence or boarding. Earlier dicta in Mercado v. Court of Appeals and Exconde v. Capuno requiring boarding were overruled as inconsistent with the statute’s purpose.
In Loco Parentis and Duty of Supervision
Teachers and heads of vocational-technical schools stand in loco parentis and must exercise reasonable supervision (Arts. 349, 350, 352) over students while in their protective custody. Failure to provide adequate vigilance and precautions against foreseeable harm, including violence among students, presumes culpa in vigilando and gives rise to liability.
Burden of Proof for Exemption
Under the last paragraph of Article 2180, school officials may exculpate themselves only by proving they exercised “all the diligence of a good father of a family to prevent damage.” The defendants failed to meet that burden; hence, liability attaches.
Adjustment of Death Indemnity
Invoking People v. Pantoja, the Court increased the minimum compensatory damages for death caused by q
Case Syllabus (G.R. No. 239090)
Procedural Posture
- Appeal in forma pauperis on pure questions of law from the Court of First Instance of Manila.
- Plaintiffs-appellants (spouses Palisoc) filed an action for damages on May 19, 1966, following the death of their son on March 10, 1966.
- Trial court rendered judgment in favor of plaintiffs against defendant Daffon and absolved other school officials; appealed by spouses Palisoc.
Parties
- Plaintiffs-Appellants: Spouses Moises P. Palisoc and Brigida P. Palisoc, parents of deceased student Dominador Palisoc.
- Defendant Virgilio L. Daffon: Fellow student who inflicted fatal injuries.
- Defendant Antonio C. Brillantes: Member of the Board of Directors; former single proprietor under Act No. 3883.
- Defendant Teodosio V. Valenton: President of Manila Technical Institute.
- Defendant Santiago M. Quibulue: Instructor of the deceased’s class.
Facts of the Case
- On March 10, 1966, between 2:00 and 3:00 p.m., Dominador Palisoc, Virgilio Daffon, and Desiderio Cruz were in the school’s ground-floor laboratory during recess.
- Daffon commented that Palisoc was “acting like a foreman”; Palisoc responded with a slight slap.
- In retaliation, Daffon delivered a strong blow to Palisoc’s face and multiple fist blows to his stomach.
- During the struggle, Palisoc fell face-down upon an engine block, became pale, fainted, and never regained consciousness.
- Autopsy by Dr. Angelo Singian: traumatic fracture of left 6th and 7th ribs, contusion of pancreas and stomach with intra-gastric hemorrhage, slight subarachnoid hemorrhage; cause of death “shock due to traumatic fracture … and internal contusions,” “probably by strong fist blows.”
- Sole eyewitness Desiderio Cruz credited; Daffon’s self-exculpatory version rejected.
Trial Court Findings and Decision
- Held Daffon liable for quasi-delict under Article 2176, Civil Code.
- Found Article 2180 inapplicable to school officials because no evidence Daffon “