GR 84698; (February, 1992) (Digest)
G.R. No. 84698 February 4, 1992
PHILIPPINE SCHOOL OF BUSINESS ADMINISTRATION, ET AL., petitioners, vs. COURT OF APPEALS, HON. REGINA ORDOÑEZ-BENITEZ, ET AL., respondents.
FACTS
The parents of Carlitos Bautista, a third-year commerce student at the Philippine School of Business Administration (PSBA), filed a damages suit against PSBA and its corporate officers after Carlitos was stabbed to death by assailants from outside the school on its second-floor premises. The complaint alleged negligence and lack of security precautions on the part of the school and its officials. The petitioners moved to dismiss, arguing that under Article 2180 of the Civil Code, an academic institution is not liable for the acts of non-students, citing established jurisprudence.
The trial court denied the motion to dismiss, a decision affirmed by the Court of Appeals. The appellate court ruled that Article 2180 should be applied broadly to all educational institutions and that the issue of whether the school observed the diligence of a good father of a family to prevent damage is a matter for trial. The petitioners elevated the case to the Supreme Court via this petition.
ISSUE
Whether the complaint against PSBA and its officers states a cause of action, considering the assailants were not students of the school.
RULING
The Supreme Court denied the petition and ordered the trial to proceed, but on a different legal basis than that used by the Court of Appeals. The Court clarified that the doctrine of in loco parentis under Article 2180 in relation to Article 2176 (quasi-delict) applies only when the damage is caused by the school’s own pupils or students. Since the assailants were outsiders, liability cannot be anchored on this quasi-delict provision.
However, the absence of quasi-delict liability does not automatically exculpate the petitioners. A contractual relation exists between the school and the student. By accepting Carlitos for enrollment, PSBA undertook not only to provide education but also an obligation to ensure a safe and secure environment conducive to learning. This includes taking adequate steps to maintain peace and order within the campus. The breach of this contractual obligation due to negligence—defined as the omission of the required diligence under the circumstances—can give rise to liability.
As the case was still at the motion to dismiss stage, the factual question of whether PSBA breached its contractual duty by failing to provide adequate security remains to be proven during a full trial on the merits. Therefore, the complaint sufficiently states a cause of action for culpa contractual, warranting a full hearing.