Case Summary (G.R. No. 66207)
Factual Background
On March 22, 1983, Maximino Soliman, Jr., who was a regular student at Republic Central Colleges, initiated a civil action for damages against the Colleges, R.L. Security Agency Inc., and security guard Jimmy Solomon. The complaint detailed an assault whereby Solomon, in his capacity as a security guard, attacked Soliman with a firearm, resulting in severe injuries that required medical attention and a recovery period of three to four months.
Motion to Dismiss
In response, Republic Central Colleges filed a motion to dismiss the complaint, arguing that it could not be held liable as Solomon was not its employee but rather an employee of R.L. Security Agency Inc. The Colleges contended that Article 2180 of the Civil Code, which outlines vicarious liability, did not apply since Solomon was not a pupil, student, or apprentice of the school.
Trial Court's Decision
On November 29, 1983, the respondent Judge granted the motion to dismiss, ruling that the Colleges could not be held accountable for the actions of Solomon due to the absence of an employer-employee relationship. The petitioner attempted to have this decision reconsidered, but to no avail.
Legal Contentions
The petitioner filed a Petition for Certiorari and Prohibition, asserting that the trial judge abused discretion by disregarding Article 2180 and other related articles. Article 2180 states that employers are liable for damages caused by their employees during the scope of their duties. The petitioner emphasized that the security guard’s actions were connected to his employment, and therefore, the Colleges should be vicariously liable.
Employer-Employee Relationship
The ruling established the legal principle affirming that liability for the acts of security personnel lies with the agency that employs them. Since Solomon was exclusively employed by R.L. Security Agency, the Colleges, as the client, bore no vicarious liability for Solomon’s actions, despite the security guard's assignment to the school premises.
Referenced Jurisprudence
The court differentiated the current case from precedents wherein schools could be held liable under Article 2180 when the parties involved included students. The cited case of Palisoc v. Brillantes involved an assault between two students, allowing for the application of vicarious responsibility due to the school’s supervisory role. In contrast, Jimmy Solomon was not a student, eliminating the basis for vicarious liability against the Colleges.
Contractual Obligations
The court acknowledged that while institutions are obliged to provide a safe environment for students, liability for security-related incidents involving outsiders or employees of a separate agency may not be directly established without clear evidence of negligence in fulfilling contractual duties. In reference to the case of Philippine School of Business Administration v. Court of Appeals, it wa
...continue readingCase Syllabus (G.R. No. 66207)
Case Background
- The case involves petitioner Maximino Soliman, Jr., represented by his judicial guardian Virginia C. Soliman, against respondents Hon. Judge Ramon Tuazon and Republic Central Colleges.
- The litigation commenced on 22 March 1983, initiated by a civil complaint for damages stemming from an incident that occurred on 13 August 1982.
- The incident took place while the petitioner, a regular enrolled student of Republic Central Colleges, was present on the school premises.
- The complaint specifically alleged that Jimmy B. Solomon, a security guard employed by R.L. Security Agency, Inc., acted unlawfully by attacking the petitioner with a .38 caliber revolver.
Allegations and Initial Proceedings
- Petitioner claimed that Solomon, in a wanton and reckless manner, attempted to shoot him, causing severe injury that required medical treatment and resulted in the petitioner’s incapacity to attend classes for three to four months.
- In response, Republic Central Colleges filed a motion to dismiss, arguing that it was not liable for the actions of Solomon as he was not an employee of the school but rather of the R.L. Security Agency, Inc.
- The school contended that the provisions of Article 2180 of the Civil Code did not apply, as Solomon was neither a pupil nor an apprentice of the institution.
Court's Initial Ruling
- On 29 November 1983, the respondent judge granted the motion to dismiss, concluding that there was no employer-employee relationship between the Colleges and Solomon.
- The judge ruled that only the R.L. Security Ag