View full case

ST. JOSEPH'S COLLEGE v. JAYSON MIRANDA

FACTS:

This case involves a petition for review on certiorari seeking to set aside the decision of the Court of Appeals (CA) that affirmed the decision of the Regional Trial Court (RTC) in a civil case filed by respondent Jayson Val Miranda against petitioners. According to the CA's findings, on November 17, 1994, Jayson was conducting a science experiment in his class at St. Joseph College (SJC) under the supervision of petitioner Rosalinda Tabugo, his subject teacher. Tabugo left the class without adequately securing the experiment. During the experiment, Jayson, who was the assistant leader of his group, looked at the compound in the test tube with a magnifying glass. The compound spurted out and hit Jayson's eye and the bodies of some of his classmates. This incident resulted in chemical burns to Jayson's eyes, to which he required surgery and medical treatment. Additionally, Jayson's mother, who was working abroad, incurred expenses to come back home. Jayson and his parents suffered mental anguish and wounded feelings. Jayson demanded payment of medical and other expenses from the petitioners, but they failed to comply. Accordingly, Jayson filed a complaint for damages. The petitioners argued that Jayson was negligent for not following instructions and looking into the test tube before the compound had cooled off.

After trial, the RTC ruled in favor of Jayson, ordering the petitioners to pay actual damages, mitigated moral damages, attorney's fees, and costs of suit. The petitioners appealed to the CA, but the CA affirmed the RTC's decision. The petitioners then filed a petition for review to the Supreme Court, arguing that the CA erred in finding them liable. However, the Supreme Court found no reason to depart from the lower courts' rulings and rejected the petitioners' arguments.

ISSUES:

  1. Whether the proximate cause of Jayson's injury was his own act of looking at the heated test tube in complete disregard of instructions given prior to the experiment.

  2. Whether the award of actual damages, moral damages, and attorney's fees to Jayson was justified.

  3. Whether the petitioners' counterclaim should have been upheld.

RULING:

  1. The Supreme Court found that the proximate cause of Jayson's injury was not his own negligence but the sudden and unexpected explosion of the chemicals during the science experiment. The Court held that the petitioners were negligent for failing to exercise the required degree of care, prudence, and caution expected of them in preventing such injuries.

  2. The Supreme Court affirmed the lower courts' awards of actual damages, moral damages, and attorney's fees to Jayson, finding them justified and supported by the evidence.

  3. The Supreme Court upheld the lower courts' denial of the petitioners' counterclaim.

PRINCIPLES:

  1. Duty of Care in Educational Institutions Schools, its administrators, and teachers have special parental authority and responsibility over their students and are expected to exercise a high degree of care, prudence, caution, and foresight to prevent injuries.

  2. Proximate Cause The proximate cause of the injury must have a direct causal connection to the negligent act or omission. Remote causes or contributory negligence of the victim do not absolve the primary negligent party of liability.

  3. Liability of Schools Under Article 218 and Article 2180 of the Civil Code, schools and their officials are liable for damages caused by negligence as long as the students are under their supervision or custody.

  4. Factual Findings Findings of the trial court and the appellate court, especially when consistent, are accorded the highest degree of respect and are generally conclusive between the parties.

  5. Award of Damages Awards for actual damages, moral damages, and attorney's fees necessitate sufficient evidence and must be justified by the circumstances of the case.

  6. Command Responsibility Higher officials within educational institutions can be held liable for the negligent acts of their subordinates under the doctrine of command responsibility.