GR 143363; (February, 2002) (Digest)
G.R. No. 143363 ; February 6, 2002
ST. MARY’S ACADEMY, petitioner, vs. WILLIAM CARPITANOS and LUCIA S. CARPITANOS, GUADA DANIEL, JAMES DANIEL II, JAMES DANIEL, SR., and VIVENCIO VILLANUEVA, respondents.
FACTS
Spouses William and Lucia Carpitanos filed a damages suit against St. Mary’s Academy, minor student James Daniel II and his parents, and vehicle owner Vivencio Villanueva following the death of their son, Sherwin. Sherwin, a student of St. Mary’s Academy, died from injuries sustained in a vehicular accident. The accident occurred while Sherwin and other students were participating in a school-authorized enrollment campaign, traveling in a Mitsubishi jeep owned by Villanueva and driven by the 15-year-old Daniel. The trial court held the school principally liable for damages, citing its special parental authority over the students during the activity. The Court of Appeals affirmed this liability, finding the school negligent for allowing a minor to drive and for not having a teacher accompany the students.
ISSUE
Whether the Court of Appeals erred in holding petitioner St. Mary’s Academy liable for damages arising from the student’s death.
RULING
The Supreme Court reversed the rulings of the lower courts and absolved St. Mary’s Academy of liability. While the school exercises special parental authority over students during authorized activities under Article 218 of the Family Code, such authority does not automatically result in liability. For liability to attach under Article 219, the negligent act or omission of the entity must be the proximate cause of the injury. Proximate cause is that cause which, in a natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury.
The Court found that the proximate cause of the fatal accident was not the school’s alleged negligence in supervision, but a mechanical failure—the detachment of the steering wheel guide of the jeep. This fact was admitted by respondents Daniel and Villanueva in their pleadings. Since the immediate and direct cause of the mishap was a vehicular defect, the chain of causation linking any oversight by the school to the death was broken. Consequently, the school’s conduct was not the proximate cause of the injury. The Court ruled that liability, if any, should fall upon the registered owner of the vehicle under the principle of respondeat superior, and remanded the case to the trial court for determination of the liability of the other defendants, excluding the academy.