Title
St. Mary's Academy vs. Carpitanos
Case
G.R. No. 143363
Decision Date
Feb 6, 2002
A student died in a vehicular accident during a school enrollment drive; the Supreme Court absolved St. Mary’s Academy, ruling the proximate cause was a mechanical defect, not school negligence.

Case Summary (G.R. No. 143363)

Key Dates and Procedural Posture

  • Complaint for damages filed: June 9, 1995.
  • Enrollment drive: 13–20 February 1995; accident occurred during this period.
  • Trial court decision (Regional Trial Court, Branch 6, Dipolog City): February 20, 1997 — awarded indemnity, actual and moral damages, attorney’s fees, and costs against St. Mary’s Academy (with subsidiary liability of parents of the minor); absolved the minor and absolved the vehicle owner.
  • Court of Appeals decision: February 29, 2000 — affirmed trial court judgment except for reduction of actual damages to P25,000.00; motion for reconsideration denied May 22, 2000.
  • Petition for certiorari filed in the Supreme Court: July 17, 2000; Supreme Court resolution granting due course: July 16, 2001.
  • Supreme Court decision reversing the Court of Appeals and trial court: February 6, 2002.

Applicable Law and Constitutional Basis

Constitutional basis: 1987 Philippine Constitution (decision rendered in 2002).
Statutory provisions applied: Family Code of the Philippines, Article 218 (special parental authority and responsibility of schools and caretakers) and Article 219 (principal and solidary liability of those exercising special parental authority for acts or omissions of unemancipated minors, with subsidiarily liability of parents or guardians, subject to proof of proper diligence). Civil Code provisions referenced: Article 2217 (moral damages recoverable when they are the proximate result of defendant’s wrongful act or omission) and Article 2208 (authority to award attorney’s fees requires factual, legal and equitable justification). Relevant jurisprudential principles concerning proximate cause and registered-owner liability were applied as articulated in the court’s reasoning.

Facts Found by the Courts

St. Mary’s Academy conducted an enrollment campaign for school year 1995–1996 that included visitation of public schools. Sherwin Carpitanos, a student of St. Mary’s, participated in the campaigning group. On the day of the accident, Sherwin and other high-school students were riding in a Mitsubishi jeep owned by respondent Vivencio Villanueva. The jeep was reportedly being driven by James Daniel II, then 15 years old, who was a student of St. Mary’s. The jeep allegedly “turned turtle”; Sherwin died from injuries sustained in that accident. Respondent parties acknowledged documentary and testimonial evidence indicating that the immediate cause of the accident was the detachment of the steering wheel guide of the jeep. Evidence also showed that Ched Villanueva had possession and control of the jeep and had allowed James Daniel II to drive it at the time of the accident.

Trial Court Disposition and Court of Appeals Ruling

The trial court rendered judgment against St. Mary’s Academy ordering payment of P50,000.00 (indemnity for loss of life), P40,000.00 (actual damages for burial and related expenses), P10,000.00 (attorney’s fees), and P500,000.00 (moral damages), with costs. The court adjudged James Daniel II absolved from liability and made the parents subsidiarily liable should St. Mary’s prove insolvent; it also absolved the vehicle owner, Vivencio Villanueva. The Court of Appeals affirmed the trial court’s ruling in substance but reduced the award for actual damages to P25,000.00.

Issues Presented to the Supreme Court

  1. Whether the Court of Appeals erred in holding St. Mary’s Academy liable for damages for Sherwin Carpitanos’s death.
  2. Whether the Court of Appeals erred in affirming the award of moral damages against St. Mary’s Academy.

Legal Standard on Special Parental Authority and Proximate Cause

Article 218 confers special parental authority and responsibility on schools, their administrators and teachers, and entities engaged in child care over minors while under their supervision, applying to authorized activities on or off school premises. Article 219 provides that those exercising special parental authority are principally and solidarily liable for damages caused by acts or omissions of the unemancipated minor under their supervision, with parents or guardians subsidiarily liable; liability does not attach if those exercising authority prove they exercised the proper diligence required under the circumstances. Crucially, liability under these provisions requires a causal nexus: the negligent act or omission of the person exercising special parental authority must be the proximate cause of the injury. The Court reiterated established principles defining proximate cause as the cause which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury and without which the result would not have occurred. Moral damages are recoverable only if they are the proximate result of the defendant’s wrongful act or omission. The award of attorney’s fees under Article 2208 of the Civil Code is an exception and demands factual, legal and equitable justification.

Court’s Analysis Applying the Law to the Facts

The Supreme Court examined whether the record established that any negligent act or omission by St. Mary’s Academy was the proximate cause of the accident and Sherwin’s death. The Court found the respondents failed to prove such causal connection. Key points in the factual record supporting that finding were: admissions by respondents that the immediate cause of the accident was mechanical—the detachment of the steering wheel guide; the traffic investigator’s report and testimony attributing the accident to that mechanical defect; and the absence of evidence connecting the school’s conduct (for example, permitting a minor to drive under circumstances within the school’s control) to the mechanical failure. The record further indicated that possession and control of the jeep was with Ched Villanueva, who allowed the minor to drive; there was no showing that the school had authorized or allowed the vehicle owner’s vehicle to be driven by the minor as part of the school’s activities in a manner that made the school the proximate cause. Given that the mechanical defect (or alternatively the independent negligence of the minor’s parents in permitting the minor to drive) constituted an efficient

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