GR 182353; (June, 2010) (Digest)
G.R. No. 182353 ; June 29, 2010
ST. JOSEPH’S COLLEGE, SR. JOSEPHINI AMBATALI, SFIC, and ROSALINDA TABUGO, Petitioners, vs. JAYSON MIRANDA, represented by his father, RODOLFO S. MIRANDA, Respondent.
FACTS
On November 17, 1994, a Grade 6 science class at St. Joseph’s College conducted an experiment involving heating a compound of sulphur and iron filings. The teacher, Rosalinda Tabugo, left the class unsupervised during the experiment. While the compound was still heated, respondent Jayson Miranda, the assistant leader of his group, looked into the test tube using a magnifying glass. The compound spurted, chemically burning his left eye, necessitating surgery and medical expenses. His mother, working abroad, had to return home, incurring travel costs and lost income.
Petitioners contended that before the experiment, students were given strict written and verbal instructions not to look into the test tube until the compound cooled. They alleged Jayson, a person of sufficient age and discretion, violated these instructions. After the incident, he even apologized to his teacher. The school advanced payment for his initial hospital bill. Jayson, through his father, filed a complaint for damages against the school and the teacher.
ISSUE
Whether petitioners are liable for damages arising from the injury sustained by Jayson during the science experiment.
RULING
Yes, petitioners are liable, but Jayson’s contributory negligence mitigates their liability. The Supreme Court affirmed the lower courts’ decisions. The pivotal legal principle is that schools and their teachers are obligated to exercise diligent supervision over students’ activities to ensure their safety. This duty is particularly heightened during potentially hazardous activities like laboratory experiments. Teacher Tabugo’s act of leaving the class unattended constituted a breach of this duty of care. This breach was the proximate cause of the accident, as adequate supervision could have prevented the students from handling the heated materials unsafely.
However, the Court also upheld the finding of contributory negligence on Jayson’s part. As a Grade 6 student, he was of sufficient age and discretion to understand and follow the explicit safety instructions. His deliberate act of looking into the heated test tube directly contravened these instructions and contributed to his own injury. Consequently, while petitioners’ negligence established their liability, Jayson’s own negligence does not absolve them but proportionately reduces the damages for which they are responsible. The awards for actual and moral damages, as well as attorney’s fees, were thus affirmed as justly apportioned.