FACTS:

This case is about the liability of a private school for the actions of an outside catechist who physically assaulted a student. The respondent, Jose Luis Inton, was a grade three student at Aquinas School. The religion teacher, Sister Margarita Yamyamin, noticed that Jose Luis left his seat to play a joke on a classmate. Yamyamin sent Jose Luis back to his seat, but he got up again to approach the same classmate. In response, Yamyamin kicked him on the legs multiple times, pulled and shoved his head on the classmate's seat, and made him copy notes from the blackboard while seated on the floor. Jose Luis and his parents, the Intons, filed an action for damages against Yamyamin and Aquinas. Yamyamin pleaded guilty to the criminal charge, and the Intons sought damages in the civil case. The Regional Trial Court ruled in Jose Luis' favor, holding Yamyamin liable for moral damages, exemplary damages, and attorney's fees. Dissatisfied, the Intons appealed to the Court of Appeals and asked for Aquinas to be held solidarily liable. The Court of Appeals found an employer-employee relationship between Aquinas and Yamyamin and made them solidarily liable. Aquinas appealed to the Supreme Court, arguing that it should not be held liable. The Supreme Court ruled in favor of Aquinas, stating that it did not have control over Yamyamin's teaching methods. However, Aquinas still had a responsibility to ensure the qualification of outside catechists and took steps to prevent misconduct. The Intons' request for an increase in damages was denied since they did not appeal the decision of the Court of Appeals. Ultimately, the Supreme Court held that Aquinas was not liable for damages.

ISSUES:

1. Whether Aquinas School is solidarily liable with Yamyamin for the damages awarded to Jose Luis Inton.

RULING:

1. The Court ruled that Aquinas School is not solidarily liable with Yamyamin for the damages awarded to Jose Luis Inton. Aquinas did not have control over Yamyamin's teaching methods as she was selected and engaged by a religious congregation to provide catechesis to the students. Aquinas took steps to ensure the qualification and proper conduct of outside catechists, and promptly relieved Yamyamin of her assignment after learning of the incident. However, Aquinas still had the responsibility to ensure that only qualified outside catechists are allowed to teach its students.

PRINCIPLES:

• The existence of an employer-employee relationship is determined by the "four-fold test" which includes the elements of selection and engagement, payment of wages, power to dismiss, and control over work. The element of control is the most crucial.

• Control refers to the right of the employer to control the work of the employee and the means and methods by which the work is accomplished.

• The employer is not solidarily liable with the employee if it does not have control over the employee's work.

• The employer still has the responsibility of taking steps to ensure that only qualified outside workers are allowed to perform the tasks assigned to them.

• The employer may be liable for damages if there is proven negligence or lack of diligence in selecting and supervising the outside worker.