AQUINAS SCHOOL, Petitioner, vs. SPS. JOSE INTON and MA. VICTORIA S. INTON, on their behalf and on behalf of their minor child, JOSE LUIS S. INTON, and SR. MARGARITA YAMYAMIN, OP, Respondents.
FACTS
In 1998, respondent Jose Luis Inton, a grade three student at petitioner Aquinas School, was disciplined by respondent Sister Margarita Yamyamin, a religion teacher who began teaching at the school in June 1998. On July 14, 1998, while Yamyamin was writing on the blackboard, Jose Luis left his seat to play a joke on a classmate. After being sent back, he did it again. Yamyamin then kicked him on the legs several times, pulled and shoved his head on the classmate’s seat, and made him copy notes while seated on the floor. The parents of Jose Luis filed a civil action for damages against Yamyamin and Aquinas School. Yamyamin also pleaded guilty in a separate criminal action for violation of Republic Act 7610. The Regional Trial Court (RTC) held Yamyamin liable for moral damages, exemplary damages, and attorney’s fees but dismissed the personal claims of the mother. On appeal, the Court of Appeals (CA) held Aquinas School solidarily liable with Yamyamin, finding an employer-employee relationship, but declined to increase the damages. Aquinas School appealed to the Supreme Court.
ISSUE
Whether the Court of Appeals was correct in holding Aquinas School solidarily liable with Yamyamin for the damages awarded to Jose Luis Inton.
RULING
The Supreme Court GRANTED the petition and SET ASIDE the decision of the Court of Appeals, holding Aquinas School not liable in damages.
The Court ruled that the CA erred in finding Aquinas solidarily liable based on an employer-employee relationship under Article 2180 of the Civil Code. Applying the four-fold test, the most crucial element of control was absent. The school directress testified that Aquinas had an agreement with a religious congregation, which sent Yamyamin to provide catechesis, similar to how bishops designate catechists for public schools. Aquinas did not select Yamyamin, and the Intons did not refute testimony that the school lacked control over her teaching methods. Thus, no employer-employee relationship existed.
Furthermore, the Court found that Aquinas exercised due diligence in overseeing Yamyamin. The school: (1) verified her qualifications through her transcripts and diplomas; (2) ascertained she was from a legitimate religious congregation; (3) provided her with the school’s Administrative Faculty Staff Manual and required her to attend a teaching orientation; (4) pre-approved the content of her course; and (5) had a classroom evaluation program but, due to her newness at the start of the school year, lacked sufficient opportunity to observe her before the incident. Aquinas also acted promptly to relieve her after learning of the incident. The Court concluded Aquinas was not guilty of outright neglect.
Regarding the Intons’ plea for increased damages, the Court denied it as they did not appeal the CA’s decision and sought the increase only in their comment to the petition, thus precluding affirmative relief beyond what the CA granted.
