Mother Goose Special School System, Inc. v. Spouses Palaganas [January 20, 2025]

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G.R. No. 267331 – MOTHER GOOSE SPECIAL SCHOOL SYSTEM, INC., petitioner, vs. SPOUSES SAMUEL PALAGANAS AND VILLA PALAGANAS, respondents.

M.V. LOPEZ, J.

Rule Synopsis

In quasi-delict, the negligence is direct, substantive, and independent; whereas in culpa contractual, the negligence is merely incidental to the performance of a pre-existing contractual obligation. The defense of “good father of a family” in the selection and supervision of employees is a complete defense available to employers only with respect to culpa aquiliana and not for culpa contractual. Nevertheless, the institution or school may still avoid liability by proving that the breach of its contractual obligation to the students was not due to its negligence.

Facts

In 2007, Rhys Palaganas (Rhys) was enrolled as a grade school student at Mother Goose Special School System, Inc. (Mother Goose School). During computer class, Noel Fernandez (Noel) asked Rhys to return his mechanical pencil which the latter found but Rhys failed to do so. Rhys was then punched by Noel five times and by another classmate, Mark Dy (Mark) six times. Mr. Gerald Gomez (Gomez), the teacher-in-charge, was in the comfort room during the incident.

Rhys reported the incident to teachers of Mother Goose School. His parents also complained to the school and requested an investigation. After investigation, the school concluded “that there was only teasing or rough play among Rhys, Noel, and Mark,” and no disciplinary action was taken.

Thus, Rhys’ parents filed a complaint for damages against the fathers of Noel and Mark, Mother Goose School, and several of its officers, including Mr. Gomez.

The Regional Trial Court (RTC) held Mother Goose School and Mr. Gomez solidarily liable for its negligence in handling the punching incident among its pupils, which the Court of Appeals (CA) affirmed with modifications. The CA exonerated Mr. Gomez and found Mother Goose School directly liable for the incident but reduced the amount of damages.

Issues

Should Mother Goose School be held liable in its handling of the punching incident among its pupils?

Ruling and Discussion

Yes. Mother Goose School should be held liable in its handling of the punching incident among its pupils.

Under Art. 1157 of the New Civil Code, obligations may arise from, among others, contracts or quasi-delicts. An obligation arises from from contracts, when a party binds themselves to give something or to render some service to another person, there being meeting of the minds; and from quasi-delicts, when a person’s act or omission causes damage to another, there being fault or negligence.

Here, Mother Goose School’s liability arises from the breach of its contractual obligation as an educational institution (culpa contractual) to provide and maintain a safe learning environment for its students, and not from quasi-delict. Academic institutions have a “built-in” obligation of providing a conducive atmosphere for learning, where there are no constant threats to life and limbs of the students. Thus, the school must ensure the maintenance of peace and order within the campus.

Culpa contractual is the fault or negligence in the performance of a pre-existing obligation. It is governed by Articles 1170 to 1174 of the Civil Code. The mere proof of the existence of the contract and the failure of its compliance justify, prima facie, a corresponding right of relief. Meanwhile, culpa aquiliana is the wrongful or negligent act or omission which creates a vinculum juris and gives rise to an obligation between two persons not formally bound by any other obligation. It is governed by Article 2176 of the Civil Code.

In quasi-delict, the negligence is direct, substantive, and independent; whereas in culpa contractual, the negligence is merely incidental to the performance of a pre-existing contractual obligation. The defense of “good father of a family” in the selection and supervision of employees is a complete defense available to employers only with respect to culpa aquiliana and not for culpa contractual. Nevertheless, the institution or school may still avoid liability by proving that the breach of its contractual obligation to the students was not due to its negligence.

Here, the Court agrees with the RTC and the CA that Mother Goose School was grossly negligent in handling the punching incident.

  • the teachers in Mother Goose School were ill-equipped in addressing a student’s complaints of physical harm. Rhys’ first report was ignored, while not action was taken on a second report by his classmate other than confirming with Noel and Mark that they indeed punched Rhys;
  • Mother Goose School failed to inform Rhys’ parents of the incident;
  • Mother Goose School does not have a protocol in addressing any harm committed by one student against another;
  • Mother Goose School conducted an investigation only upon the request and prodding of Rhys’s father;
  • Mother Goose School did not update Rhys’s parents regarding the investigation;
  • the results of Mother Goose School’s investigation was replete with inaccurate information, and no disciplinary action was taken against the offenders.

Since Mother Goose School’s negligence arises from an existing contractual obligation, its defense that it exercised due diligence in the selection and hiring of employees under Article 2180 of the Civil Code, which is applicable only for quasi-delicts, must fail.

dispositive

Petition dismissed. Decision of the CA affirmed with modification.

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