Title
St. Francis High School vs. Court of Appeals
Case
G.R. No. 82465
Decision Date
Feb 25, 1991
A 13-year-old drowned during a school picnic; parents sued for negligence. Courts ruled teachers exercised due diligence, picnic was private, and school/principal not liable. No damages awarded.

Case Summary (G.R. No. 82465)

Factual Background and Filing of Complaint

The deceased, Ferdinand Castillo, a 13-year-old freshman student of Section I-C at St. Francis High School, was not initially allowed by his parents to join a picnic organized by Class I-B and I-C at Talaan Beach. He was permitted only to bring food to teachers but returned unchecked to join the picnic on persuasion by teachers. During the picnic, Ferdinand attempted to rescue a drowning female teacher but himself drowned. Despite rescue efforts by some teachers and first-aid administered by physical education instructors, Ferdinand was pronounced dead upon arrival at the hospital. The respondents filed a damage claim against the school, its principal, and the teachers presently supervising, alleging negligence that led to Ferdinand’s death.

Trial Court’s Findings and Initial Decision

The Regional Trial Court found the teachers—Connie Arquio, Tirso de Chavez, Luisito Vinas, Yoly Jaro, Nida Aragones, and Patria Cadiz—negligent for failing to exercise due diligence as “lifeguards” and supervisors during the picnic. The court cited their inadequate safety measures, failure to test water depth, absence during crucial times (notably male teachers allegedly drinking elsewhere), and inability to prevent the drowning despite knowing the danger of the sea location. The court awarded actual damages (₱30,000), moral damages (₱20,000), and attorney’s fees (₱15,000) against all six teachers jointly and severally. However, the school, principal Benjamin Illumin, and teacher Aurora Cadorna were exonerated for lack of evidence that the picnic was school-sponsored or sanctioned.

Court of Appeals’ Ruling and Modifications

On appeal, the Court of Appeals found that although the picnic was not officially school-sponsored, it was still held under the supervision of the school's teachers who had knowledge of and acquiesced to the event without precautionary measures. Invoking Civil Code Articles 2176 and 2180, it held St. Francis High School and its principal, Benjamin Illumin, jointly and severally liable alongside the negligent teachers, emphasizing the school principal’s awareness and failure to prohibit or regulate the picnic. The Court affirmed the amounts awarded by the trial court but augmented the damages by adding exemplary damages of ₱20,000 to serve as a public exemplar. The Court further absolved teachers Yoly Jaro and Nida Aragones from liability owing to their late arrival at the picnic site and non-participation in the negligent supervision.

Petitioners’ (Teachers and School) Contentions on Review

Petitioners contended there was no negligence attributable to them, arguing that:

  • The picnic was a purely private, unsanctioned affair not performed within the scope of their employment;
  • The school and principal were improperly held liable under Article 2180 due to absence of proof that teachers acted within their assigned duties;
  • They exercised the diligence of a good father of a family, including inviting knowledgeable personnel and rendering first aid; and
  • Moral and exemplary damages were unwarranted under the circumstances.

Supreme Court’s Analysis on Negligence and Liability

The Supreme Court (majority) found no negligence imputable to petitioners. It emphasized that respondents’ own admissions evidenced parental consent for Ferdinand to join the picnic, negating claims of unauthorized participation. Importantly, the Court ruled that Article 2180 of the Civil Code, which imposes vicarious liability on employers for acts of employees performed within the scope of their assignments, was inapplicable. The picnic was neither school-sanctioned nor an extra-curricular activity; the teachers were not performing assigned duties at the time but instead engaging in a private event, removing the basis for holding school or principal liable. The Court noted that mere knowledge or acquiescence by the principal did not constitute consent or supervision to the extent required to establish liability. The teachers invoked demonstrated reasonable care, including bringing life savers and administering first aid. The Court found no sufficient grounds for moral or exemplary damages, as no fault or negligence was established against petitioners. The awards by lower courts were set aside, while dismissal of counterclaims was affirmed.

Supreme Court’s Dissenting Opinion

Justice Padilla dissented, expressing concern for the lack of redress for the bereaved parents. He concurred with findings of negligence against four teachers (Arquio, De Chavez, Vinas, Cadiz), citing their failure to adequately supervise beforehand—including absence of water depth checks, absence from immediate swimming area, and inattentiveness during the picnic (some engaged in drinking). Although conceding their diligent efforts to revive Ferdinand post-drowning, he doubted their promptness in procuring medical assistance. He argued that knowledge and tacit consent by the principal and school officials created implied authorization, thus rendering the school and its administrators vicariously liable under Articles 2176 and 2180. He rejected the majority’s fear of extending employer liability beyond the scope of duties, underscoring the special duty educational institutions owe to their minor students to ensure safety, even in extra-curricular or unsanctioned activities where school personnel participate. Further, he maintained the propriety of moral and exemplary damages based on quasi-delict liability flowing from physical injury (death). Accordingly, he voted to affirm liability and damages awards.

Legal Issues Resolved

  1. Negligence and Duty of Care: The Court examined whether the teachers breached their duty of supervision owed to minor students during the picnic. The majority found no negligence while the dissent found negligent supervision pre-incident.
  2. Scope of Employer Liability (Article 2180, Civil C

    3. ...continue reading

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