G.R. No. L-29025, October 4, 1971
Spouses Moises P. Palisoc and Brigida P. Palisoc, plaintiffs-appellants, vs. Antonio C. Brillantes and Teodosio V. Valenton, owner and President, respectively, of a school of arts and trades, known under the name and style of “Manila Technical Institute” (M.I.T.), Virgilio L. Daffon and Santiago M. Quibulue, defendants-appellees.

FACTS

The plaintiffs-appellants are the parents of Dominador Palisoc, a sixteen-year-old student at the Manila Technical Institute. On March 10, 1966, during a class recess, Dominador was in a laboratory room with classmates Virgilio Daffon and Desiderio Cruz. An altercation ensued after Daffon remarked that Palisoc was acting like a foreman. Palisoc responded by slapping Daffon slightly, prompting Daffon to retaliate with strong fist blows to Palisoc’s face and stomach. The fight continued until Palisoc stumbled, fell, and later died from internal injuries caused by the blows. The trial court found defendant Daffon liable for quasi-delict under Article 2176 of the Civil Code and awarded damages to the parents.
However, the trial court absolved the school officials—Antonio Brillantes (owner), Teodosio Valenton (president), and Santiago Quibulue (instructor)—from any liability. It applied Article 2180 of the Civil Code, which holds teachers or heads of establishments of arts and trades liable for damages caused by their pupils “so long as they remain in their custody.” Interpreting the phrase “in their custody” based on the Mercado v. Court of Appeals precedent, the court ruled it contemplated a situation where the pupil lives and boards with the teacher, such that the teacher’s control supersedes that of the parents. Finding no evidence that Daffon lived and boarded with the school officials, the court dismissed the case against them.

ISSUE

Did the trial court err in absolving the defendant school officials from liability for the tort committed by their student, Virgilio Daffon, on the school premises during a class recess?

RULING

Yes. The Supreme Court reversed the trial court’s ruling and held the school officials solidarily liable with Daffon. The Court clarified that the lower court misapplied the Mercado doctrine and the phrase “so long as they remain in their custody” in Article 2180. The legal logic establishes that the requisite “custody” referred to in the law is not equivalent to the pupil boarding with the teacher. Instead, “custody” pertains to the period when the student is under the school’s authority and supervision during activities related to their schooling.
The Court emphasized that the provision imposes a special liability on schools and their heads for the acts of their students to ensure careful supervision and vigilance. This liability attaches when the student is within the school’s premises and under its control during official functions, such as class hours or authorized recess periods. The incident occurred inside the school laboratory during a class recess, a time and place where the student was undoubtedly under the school’s disciplinary authority. Therefore, the school officials could not evade their statutory duty. The law’s intent is to protect third parties by holding educational institutions accountable for failing to exercise the proper diligence in supervising their students, a duty that exists independently of any boarding arrangement.