Title
St. Joseph's College vs. Miranda
Case
G.R. No. 182353
Decision Date
Jun 29, 2010
A grade six student suffered chemical burns during a science experiment due to inadequate supervision and safety measures. The Supreme Court held the school, its administrators, and teacher liable for negligence, affirming damages for medical expenses, emotional suffering, and litigation costs.

Case Summary (G.R. No. 157294-95)

Factual Background and Nature of Injury

On November 17, 1994, during a science experiment involving the fusion of sulfur powder and iron filings conducted at St. Joseph’s College, a chemical compound unexpectedly exploded inside a test tube. Respondent, a grade six pupil and assistant leader of his group, looked directly into the test tube with a magnifying glass before the compound had cooled. The explosion caused chemical burns to Jayson's eyes, requiring surgery and ongoing medical treatment. The injury led to expenses, mental anguish, and other losses, compelling Jayson’s parents to file a damage suit against the petitioners.

Petitioners’ Defense and Allegation of Contributory Negligence

Petitioners admitted the incident but contended that Jayson acted negligently by disobeying clear and repeated instructions not to look into the heated test tube until cooled. They argued that Jayson, being of sufficient age and understanding, caused the accident through contributory negligence and that the school and teacher should therefore not be held liable for damages or moral damages. Petitioners further disclaimed responsibility for litigation costs and counterclaimed, which the trial court denied.

Trial Court Ruling and Court of Appeals Affirmation

The Regional Trial Court (RTC) held petitioners jointly and solidarily liable for actual damages amounting to ₱77,338.25 (less an advance payment of ₱26,176.36), ₱50,000.00 as mitigated moral damages, ₱30,000.00 for attorney’s fees, and costs of suit. The Court of Appeals affirmed the RTC decision in toto, concluding that petitioners failed to exercise the degree of care and diligence required for the supervision of students and the safe conduct of hazardous experiments.

Supreme Court’s Standard of Review on Factual Findings

The Supreme Court emphasized the principle that factual findings affirmed by the Court of Appeals are accorded respect and binding character. Review by the Supreme Court is limited to instances involving grave abuse of discretion, misappreciation of facts, or findings based on untenable inferences, none of which were present in this case. The Court found no compelling reason to overturn the factual findings on negligence.

Proximate Cause of Injury and Negligence of Petitioners

The Court determined that the proximate cause of Jayson's injury was the sudden and unexpected explosion of the chemicals, not his alleged act of looking into the test tube before cooling. Petitioners failed to show that Jayson's conduct was the proximate cause of the injury. The negligence of petitioners lay in their failure to exercise prudence, caution, and foresight to prevent the accident. Specific lapses included inadequate supervision by the teacher Tabugo, absence of safety measures, lack of protective gear, and a failure by the school administration to provide a safe environment for conducting such experiments.

Responsibility and Doctrine of Command Responsibility

The Supreme Court held Sr. Josephini Ambatali liable under the doctrine of command responsibility for failing to ensure appropriate supervision and safety measures by the teacher and school. The liability of the school under the principle of respondeat superior for the negligence of its employees was also reaffirmed. The Court rejected petitioners' reliance on the “due diligence of a good father of the family” defense, underscoring the school’s inexcusable laxity in supervision and safety precautions despite its knowledge of the risks involved in laboratory experiments.

On Contributory Negligence of Jayson Miranda

Although the Court acknowledged that Jayson was partly responsible for his injury by disobeying explicit instructions, this contributory negligence did not absolve petitioners of their primary negligence. The Court applied comparative negligence principles to reduce but not eliminate petitioners’ liability, holding that petitioners must be held accountable for the damages directly caused by their failure to exercise the requisite degree of care.

Jurisprudential Distinction from St. Mary’s Academy v. Carpitanos

Petitioners cited St. Mary’s Academy v. Carpitanos to argue that Jayson’s negligence was the proximate cause. However, the Court distinguished that precedent, noting that unlike St. Mary’s—where negligence of the minor or his parents was the immediate cause and the school’s negligence was only remote—the instant case involved a foreseeable risk that the school failed to mitigate. Hence, the liability of petitioners in this case is direct and immediate.

Affirmation of Damage Awards and Denial of Counterclaim

The Supreme Court affirmed the RTC and CA’s award of actual and moral damages as well as attorney’s fees, finding them reasonable un

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