Case Summary (G.R. No. 84698)
Petitioner
Philippine School of Business Administration and its corporate officers
Respondents
Parents of Carlitos Bautista–Segunda R. Bautista and Arsenia D. Bautista–and the Court of Appeals and RTC Judge Regina Ordoñez-Benitez
Key Dates
- Incident: August 30, 1985
- RTC Denial of Motion to Dismiss: December 8, 1987; January 25, 1988 (reconsideration)
- Court of Appeals Decision: June 10, 1988; Reconsideration denied August 22, 1988
- Supreme Court Decision: February 4, 1992
Applicable Law
- 1987 Constitution of the Philippines
- Civil Code Articles 2176 (quasi-delict), 2180 (in loco parentis), 21 (acts contrary to morals, good customs or public policy), 1173 (degree of diligence)
Background
Carlitos Bautista was stabbed dead on PSBA’s second-floor premises by individuals unconnected to the school. His parents sued PSBA and its officers for negligence, recklessness, and lack of security measures under the theory of quasi-delict and in loco parentis liability.
Trial Court Proceedings
PSBA and its officers moved to dismiss, arguing that academic institutions fall outside Article 2180’s ambit regarding acts of non-students. The Regional Trial Court denied the motion and its reconsideration, finding that the complaint states a cause of action and merits trial.
Appellate Court Ruling
The Court of Appeals affirmed, holding that:
- Article 2180 adapts to modern educational systems and is not limited to vocational schools.
- Academic institutions and their heads are liable for acts causing damage unless they prove they exercised diligence akin to a “good father of a family.”
- The complaint should proceed to trial on the merits.
Issue on Appeal
Whether PSBA and its officers can be held liable under Articles 2176 and 2180 for injuries inflicted by third parties who are not their students.
Supreme Court Analysis
- In Loco Parentis Doctrine: Article 2180 imposes liability only for acts of pupils or students in the school’s custody; here, assailants were outsiders, so traditional in loco parentis does not apply.
- Contractual Relationship: Enrollment creates a contract imposing reciprocal obligations—PSBA must provide education and a conducive environment; students must observe rules.
- Obligation to Provide Security: Implicit in the contractual obligation is the duty to maintain peace and order on campus. Failure to do so may breach the contract.
- Quasi-Delict Versus Contract: Article 2176 governs extra-contractual obligations where no contract exists. However, tortious liability may arise alongside contractual liability if the same wrongful act violates Article 21 (acts contrary to morals or public policy).
- Jurisprudence:
• Air France vs. Carrascoso held that tort liability can coexist with contractual relations.
• Cangco vs. Manila Railroad established that breach of contract may also constitute a quasi-delict if the act independently causes
Case Syllabus (G.R. No. 84698)
Facts
- On 30 August 1985, Carlitos Bautista, a third-year commerce student at PSBA, was fatally stabbed on the school’s second-floor premises.
- His assailants were external elements, not students or staff of the Philippine School of Business Administration (PSBA).
- The deceased’s parents filed a civil action for damages against PSBA and its officers: President Juan D. Lim, Vice-President Benjamin P. Paulino, Treasurer/Cashier Antonio M. Magtalas, Chief of Security Col. Pedro Sacro, and Assistant Chief of Security Lt. M. Soriano.
- Plaintiffs alleged negligence, recklessness, and inadequate security measures before, during, and after the attack.
Procedural History
- Lt. M. Soriano resigned during trial and ceased to be co-defendant.
- Petitioners moved to dismiss, arguing Article 2180 Civil Code inapplicable to academic institutions; trial court denied the motion on 8 December 1987 and again on 25 January 1988 (reconsideration).
- Petitioners elevated the orders to the Court of Appeals, which affirmed both denials on 10 June 1988 and denied reconsideration on 22 August 1988.
- Petitioners filed a petition for review on certiorari before the Supreme Court.
Issue
- Whether PSBA and its officers can be held liable for a student’s death under Article 2176 (quasi-delict) and Article 2180 (in loco parentis) of the Civil Code when the assailants were not students.
Arguments of Petitioners
- Article 2180’s in loco parentis rule applies only to damage caused by pupils or apprentices in their custody; here, assailants were outsiders.
- Jurispruden