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ST. MARY’S ACADEMY v. WILLIAM CARPITANOS

FACTS:

The case involves an appeal from the decision of the Court of Appeals, as well as the resolution denying reconsideration, that held petitioner St. Mary's Academy liable for damages arising from an accident resulting in the death of a student. Spouses William Carpitanos and Lucia Carpitanos filed a case against James Daniel II, his parents, the vehicle owner Vivencio Villanueva, and St. Mary's Academy before the Regional Trial Court of Dipolog City, claiming damages for the death of their son Sherwin Carpitanos. The Regional Trial Court rendered a decision ordering St. Mary's Academy to pay various sums of money as indemnity, actual damages, attorney's fees, and moral damages to the plaintiffs, with the liability of James Daniel Sr. and Guada Daniel being subsidiary. James Daniel II, being a minor at the time and under the special parental authority of St. Mary's Academy, was absolved from paying damages. Vivencio Villanueva was absolved of any liability. St. Mary's Academy appealed the decision to the Court of Appeals, which promulgated a decision affirming the decision of the Regional Trial Court, reducing the actual damages but otherwise sustaining the judgment. St. Mary's Academy filed a motion for reconsideration, which was denied, leading to the present appeal.

ISSUES:

  1. Whether the Court of Appeals erred in holding the petitioner liable for damages for the death of Sherwin Carpitanos.

  2. Whether the Court of Appeals erred in affirming the award of moral damages against the petitioner.

RULING:

The Supreme Court reversed the decision of the Court of Appeals. The respondents failed to show that the negligence of the petitioner was the proximate cause of the death of Sherwin Carpitanos. The proximate cause of the accident was the detachment of the steering wheel guide of the jeep, not the alleged negligence of the school or the minor driver. Therefore, the petitioner, St. Mary's Academy, cannot be held liable for damages or moral damages arising from the accident.

PRINCIPLES:

  1. Special Parental Authority Under Article 218 of the Family Code, schools, their administrators, and teachers have special parental authority over minor children while under their supervision, whether inside or outside the school premises during authorized activities.

  2. Proximate Cause For liability to attach, there must be a direct and natural sequence unbroken by intervening efficient causes between the alleged negligence and the injury. The proximate cause must be shown to have a causal connection to the injury.

  3. Liability of Registered Vehicle Owner The registered owner of a vehicle is primarily responsible for injuries caused by the vehicle on highways or streets, regardless of whether the vehicle is used for public service.