St. Marys 4

St. Mary’s Academy vs.
Carpitanos Case Digest

St. Mary’s Academy vs. Carpitanos
G.R. No. 143363 February 6, 2002
Facts: Defendant-appellant St. Mary’s Academy of Dipolog City conducted an

enrollment drive for the school year 1995-1996. A facet of the enrollment
campaign was the visitation of schools from where prospective enrollees were
studying. As a student of St. Mary’s Academy, Sherwin Carpitanos was part of
the campaigning group.
Accordingly, on the fateful day, Sherwin, along with other high school students
were riding in a Mitsubishi jeep owned by defendant Vivencio Villanueva on
their way to Larayan Elementary School, Dapitan City. The jeep was driven by
James Daniel II then 15 years old and a student of the same school. Allegedly,
the latter drove the jeep in a reckless manner and as a result the jeep turned
turtle. Sherwin Carpitanos died as a result of the injuries he sustained from
the accident. The parents of Sherwin filed a case against James Daniel II and
his parents, James Daniel Sr. and Guada Daniel, the vehicle owner, Vivencio
Villanueva and St. Mary’s Academy before the RTC of Dipolog City and claimed
for damages.
Issue: Whether or not the petitioner St. Mary’s Academy is liable for damages
for the death of Sherwin Carpitanos.
Ruling: No. The Court held that for the school to be liable there must be a
finding that the act or omission considered as negligent was the proximate
cause of the injury caused because of negligence, must have causal connection
to the accident. There is no showing of such.
Hence, with the overwhelming evidence presented by petitioner and the

respondent Daniel spouses that the accident occurred because of the
detachment of the steering wheel guide of the jeep, it is not the school, but the
registered owner of the vehicle who shall be held responsible for damages for
the death of Sherwin Carpitanos.
------
Additional Facts and Legal Basis para sa Recit
Under Article 218 of the Family Code, the following shall have special parental
authority over a minor child while under their supervision, instruction or
custody: (1) the school, its administrators and teachers; or (2) the individual,
entity or institution engaged in child... care. This special parental authority
and responsibility applies to all authorized activities, whether inside or outside
the premises of the school, entity or institution. Thus, such authority and
responsibility applies to field trips, excursions and other affairs of... the pupils
and students outside the school premises whenever authorized by the school or
its teachers.
Under Article 219 of the Family Code, if the person under custody is a minor,
those exercising special parental authority are principally and solidarily liable
for damages caused by the acts or omissions of the unemancipated minor while
under their supervision, instruction, or... custody
However, for petitioner to be liable, there must be a finding that the act or
omission considered as negligent was the proximate cause of the injury caused
because the negligence must have a causal connection to the accident.[11]
"In order that there may be a recovery for an injury, however, it must be shown
that the 'injury for which recovery is sought must be the legitimate
consequence of the wrong done; the connection between the negligence and the
injury must be a direct and natural... sequence of events, unbroken by
intervening efficient causes.' In other words, the negligence must be the
proximate cause of the injury. For, 'negligence, no matter in what it consists,
cannot create a right of action unless it is the proximate cause of the injury...
complained of.' And 'the proximate cause of an injury is that cause, which, in
natural and continuous sequence, unbroken by any efficient intervening cause,
produces the injury, and without which the result would not have occurred.'"
In this case, the respondents failed to show that the negligence of petitioner
was the proximate cause of the death of the victim.
In their comment to the petition, respondents Daniel spouses and Villanueva
admitted the documentary exhibits establishing that the cause of the accident
was the detachment of the steering wheel guide of the jeep. Hence, the cause
of the accident was not the recklessness... of James Daniel II but the
mechanical defect in the jeep of Vivencio Villanueva. Respondents, including
the spouses Carpitanos, parents of the deceased Sherwin Carpitanos, did not
dispute the report and testimony of the traffic investigator who stated that the
cause of the... accident was the detachment of the steering wheel guide that
caused the jeep to turn turtle.
Significantly, respondents did not present any evidence to show that the
proximate cause of the accident was the negligence of the school authorities, or
the reckless driving of James Daniel II. Hence, the respondents' reliance on
Article 219 of the Family Code that "those... given the authority and
responsibility under the preceding Article shall be principally and solidarily
liable for damages caused by acts or omissions of the unemancipated minor"
was unfounded.
Further, there was no evidence that petitioner school allowed the minor James
Daniel II to drive the jeep of respondent Vivencio Villanueva. It was Ched
Villanueva, grandson of respondent Vivencio Villanueva, who had possession
and control of the jeep. He was driving... the vehicle and he allowed James
Daniel II, a minor, to drive the jeep at the time of the accident.
Considering that the negligence of the minor driver or the detachment of the
steering wheel guide of the jeep owned by respondent Villanueva was an event
over which petitioner St. Mary's Academy had no control, and which was the
proximate cause of the accident, petitioner may... not be held liable for the
death resulting from such accident.
WHEREFORE, the Court REVERSES and SETS ASIDE the decision of the
Court of Appeals[18] and that of the trial court.[19] The Court remands the
case to the trial court for determination of the liability of defendants,
excluding... petitioner St. Mary's Academy, Dipolog City.

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St. Mary’s Academy vs.

Carpitanos Case Digest

Facts: Defendant-appellant St. Mary’s Academy of Dipolog City conducted an

Hence, with the overwhelming evidence presented by petitioner and the

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