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 case originated from a fatal stabbing incident involving students of the Manila Technical Institute. The victim, Dominador Palisoc, died from injuries inflicted by a fellow student, Virgilio Daffon, during an altercation on the school premises. The victim’s parents sued the school’s owner, president, and the student-assailant for damages. The trial court dismissed the complaint against the school officials, leading to this appeal. The core legal question revolved around the liability of school heads and teachers for the tortious acts of their students under Article 2180 of the Civil Code.
A pivotal issue was whether the school’s liability under Article 2180, which holds teachers or heads of establishments liable for damages caused by their pupils “so long as they remain in their custody,” applies only to minor students. The appellees, relying on the Mercado v. Court of Appeals precedent, argued for a restrictive interpretation, limiting “custody” to situations akin to boarding where the school exercises plenary control, and suggesting the liability should not extend to students of majority age.

ISSUE

Whether the civil liability of teachers and heads of establishments of arts and trades under Article 2180 of the Civil Code is limited only to damages caused by their minor pupils and students.

RULING

No. The separate concurring opinion of Justice J.B.L. Reyes, which elucidates the majority’s legal logic, clarifies that the liability under Article 2180 is not restricted to minor students. The plain text of the law is decisive. Article 2180 explicitly mentions minority only when describing the liability of parents and guardians. It states parents are responsible for damages caused by their “minor children,” and guardians are liable for “minors or incapacitated persons.” In contrast, the clause concerning teachers and school heads imposes liability for damages caused by “pupils and students or apprentices” without any qualifying age limit.
This deliberate textual difference indicates the legislature’s intent not to confine the teachers’ liability to acts of minors. The principle ubi voluit dixit, ubi noluit tacuit (where the law willed, it spoke; where it did not will, it remained silent) applies. Furthermore, the rationale for liability is based on the custodial supervision and disciplinary authority the school exercises over students by virtue of their enrollment and attendance, which exists regardless of the student’s age. While the degree of control over an adult student may differ from that over a minor—affecting the assessment of whether the school exercised the diligence of a good father of a family to prevent damage—it does not negate the existence of the underlying responsibility. The dissenting view’s equation of “custody” with the parental condition of “living in their company” is rejected as an unwarranted judicial insertion of a limitation not found in the statute.