View full case

PHILIPPINE SCHOOL OF BUSINESS ADMINISTRATION v. CA

FACTS:

A stabbing incident on 30 August 1985 caused the death of Carlitos Bautista while on the premises of the Philippine School of Business Administration (PSBA). The parents of the deceased filed a suit for damages against PSBA and its corporate officers, alleging negligence, recklessness, and lack of security precautions. The suit also impleaded the President, Vice President, Treasurer/Cashier, Chief of Security, and Assistant Chief of Security of PSBA. It was established that the assailants were not members of the school's academic community. The defendants filed a motion to dismiss, arguing that academic institutions are beyond the scope of liability under Article 2180 of the Civil Code. The trial court denied the motion to dismiss, which was affirmed by the appellate court. The defendants now seek a reversal of the decision.

ISSUES:

  1. Whether or not the complaint states a cause of action against the defendants.

  2. Whether or not the defendants can be held liable under Article 2180 of the Civil Code.

RULING:

  1. The complaint states a cause of action against the defendants. The defendants sought to have the suit dismissed, claiming that they are not liable under Article 2180 of the Civil Code. However, the trial court and the appellate court both denied the motion to dismiss, stating that the complaint should be tried on its merits.

  2. The defendants cannot be held liable under Article 2180 of the Civil Code. The article establishes the rule of in loco parentis, which holds teachers and heads of the school staff liable for damages caused by the acts of students under their custody. However, in this case, the assailants of the victim were not students of the school. Therefore, the school cannot be held liable under Article 2180.

PRINCIPLES:

  • Article 2180 of the Civil Code establishes the rule of in loco parentis, holding teachers and heads of the school staff liable for damages caused by the acts of students under their custody.

  • In order for an educational institution to be held liable under Article 2180, the damage should have been caused by pupils or students of the institution.

  • When an academic institution accepts students for enrollment, a contract is established between them, resulting in bilateral obligations. The school undertakes to provide the student with an education.