G.R. No. 222740 . September 28, 2016.
ST. LUKE’S COLLEGE OF MEDICINE-WILLIAM H. QUASHA MEMORIAL FOUNDATION, DR. BRIGIDO L. CARANDANG, AND DR. ALEJANDRO P. ORTIGAS, PETITIONERS, VS. SPOUSES MANUEL AND ESMERALDA PEREZ AND SPOUSES ERIC AND JURISITA QUINTOS, RESPONDENTS.

FACTS

In 2010, petitioner St. Luke’s College of Medicine sent four fourth-year medical students, including the daughters of the respondent parents, to complete a clinical clerkship at a community clinic in Cabiao, Nueva Ecija. The students were housed on the clinic’s second floor. In the early morning of February 9, a fire broke out, resulting in the deaths of three female students, including the respondents’ daughters, due to smoke inhalation. The Bureau of Fire Protection initially certified the fire as accidental due to unattended cooking. Dissatisfied, the respondents sought an NBI investigation, which concluded the fire was caused by faulty electrical wiring and that the clinic’s construction violated the Revised Fire Code. The respondents filed a civil case for damages against St. Luke’s and its administrators, alleging negligence and breach of contractual obligation to ensure student safety.
The Regional Trial Court dismissed the complaint, ruling the respondents failed to prove the school’s negligence caused the fire and that the students’ alleged contributory negligence (drinking alcohol) barred recovery. The Court of Appeals reversed this decision, finding the petitioners negligent in their contractual duty to provide safe housing. The CA held that the students’ actions did not constitute proximate cause and remanded the case for determination of damages. The petitioners elevated the case to the Supreme Court.

ISSUE

Whether the petitioners are liable for damages arising from a breach of their contractual obligation to ensure the safety and security of their students.

RULING

Yes, the petitioners are liable. The Supreme Court affirmed the CA’s decision, emphasizing the existence of an enrollment contract that created an obligation on the part of the school to ensure the students’ safety. The Court applied the contract law principle that a party injured by a breach is entitled to recompense. The petitioners’ duty included a thorough inspection of the housing facilities for compliance with safety standards. Their failure to do so, as evidenced by the NBI finding of fire code violations and faulty wiring, constituted a breach of this contractual duty.
The Court rejected the defense of fortuitous event, as the negligence of the petitioners contributed to the occurrence. It also dismissed the claim of the students’ contributory negligence as the proximate cause. The act of drinking alcohol, even if proven, was not the efficient cause of the fire; the established cause was faulty wiring. The petitioners’ contractual breach created a new duty to make recompense to the injured parties. Consequently, the Supreme Court denied the petition and upheld the CA’s ruling, remanding the case for the reception of evidence on the proper amount of damages to be awarded.