St. Joseph's College v. Miranda - Escano

AUTHOR: ESCANO moved it close and towards the eye of [Jayson].
At that instance,
CASE TITLE: St. Joseph’s College v. Miranda GR # 182353 June 29, 2010 the compound in the test tube spurted out and several particles
PONENTE: Nachura, J. of which hit [Jaysons] eye and the different parts of the bodies of
TOPIC: Negligence; Diligence of a good father of a family some of his group mates.
CASE LAW/ DOCTRINE: 3. As a result thereof, [Jaysons] eyes were chemically burned,
1) To be liable, there must be a finding that the act or omission particularly his left eye, for which he had to undergo surgery and
considered as negligent was the proximate cause of the injury had to spend for his medication. Upon filing of this case [in] the
caused because the negligence must have a causal connection to lower court, [Jaysons] wound had not completely healed and still
the accident. had to undergo another surgery.
2) Art. 218. The school, its administrators and teachers, or 4. On the other hand, [petitioners SJC, Sr. Josephini Ambatali, SFIC,
the individual, entity or institution engaged in child care and Tabugo] alleged that [Jayson] and his classmates were given
shall have special parental authority and responsibility strict instructions to follow the written procedure for the
over the minor child while under their supervision, experiment and not to look into the test tube until the heated
instruction or custody. compound had cooled off. [Jayson], however, a person of
3) Authority and responsibility shall apply to all authorized sufficient age and discretion and completely capable of
activities whether inside or outside the premises of the understanding the English language and the instructions of his
school, entity or institution. teacher, without waiting for the heated compound to cool off, as
4) Art. 2180. The obligation imposed by Article 2176 is required in the written procedure for the experiment and as
demandable not only for ones own acts or omissions, but repeatedly explained by the teacher, violated such instructions
also for those of persons for whom one is responsible. and took a magnifying glass and looked at the compound, which
5) Lastly, teachers or heads of establishments of arts and at that moment spurted out of the test tube, a small particle
trades shall be liable for damages caused by their pupils hitting one of [Jaysons] eyes.
and students or apprentices, so long as they remain in 5. RTC: judgment is hereby rendered in favor of [Jayson] and against
their custody. [petitioners]. This Court orders and holds the [petitioners] joint[ly]
and solidarily liable to pay [Jayson].
FACTS: 6. CA : CA affirmed in toto the ruling of the RTC.
1. Inside St. Joseph Colleges [SJCs] premises, the class to which
[respondent Jayson Val Miranda] belonged was conducting a ISSUE(S):
science experiment about fusion of sulphur powder and iron 1. W/N THE PROXIMATE CAUSE OF JAYSONS INJURY WAS HIS OWN
fillings under the tutelage of [petitioner] Rosalinda Tabugo, she ACT OF LOOKING AT THE HEATED TEST TUBE BEFORE THE
being the subject teacher and employee of [petitioner] SJC. The COMPOUND HAD COOLED IN COMPLETE DISREGARD OF
adviser of [Jaysons] class is x x x Estefania Abdan. INSTRUCTIONS GIVEN PRIOR TO THE EXPERIMENT.
2. Tabugo left her class while it was doing the experiment without HELD: No. There is no reason to depart from the uniform rulings of the
having adequately secured it from any untoward incident or lower courts that petitioners were negligent since they all failed to exercise
occurrence. In the middle of the experiment, [Jayson], who was the required reasonable care, prudence, caution and foresight to prevent
the assistant leader of one of the class groups, checked the result or avoid injuries to the students.
of the experiment by looking into the test tube with magnifying RATIO:
glass. The test tube was being held by one of his group mates who
 As found by both lower courts, the proximate cause of Jaysons
injury was the concurrent failure of petitioners to prevent the
foreseeable mishap that occurred during the conduct of the
science experiment. Petitioners were negligent by failing to
exercise the higher degree of care, caution and foresight
incumbent upon the school, its administrators and teachers.
 Both the lower courts similarly concluded that the mishap which
happened during the science experiment was foreseeable by the
school, its officials and teachers. This neglect in preventing a
foreseeable injury and damage equates to neglect in exercising
the utmost degree of diligence required of schools, its
administrators and teachers, and, ultimately, was the proximate
cause of the damage and injury to Jayson.
 As earlier discussed, the proximate cause of [Jaysons] injury was
the explosion of the heated compound independent of any
efficient intervening cause. The negligence on the part of
[petitioner] Tabugo in not making sure that the science
experiment was correctly conducted was the proximate cause or
reason why the heated compound exploded and injured not only
[Jayson] but his classmates as well. However, [Jayson] is partly
responsible for his own injury, hence, he should not be entitled to
recover damages in full but must likewise bear the consequences
of his own negligence. [Petitioners], therefore, should be held
liable only for the damages actually caused by their negligence.
 Hence, SC affirmed CA ruling.

St. Joseph's College v. Miranda - Escano

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St. Joseph's College v. Miranda - Escano

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AUTHOR: ESCANO moved it close and towards the eye of [Jayson].

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