Pasco v. Court of First Instance of Bulacan, Branch V, Sta. Maria
NEW DOCTRINEFacts
The Antecedents: On August 24, 1979, petitioner Reynaldo Pasco, while walking inside the campus of Araneta University after attending classes, was accosted and mauled by a group of Muslim students led by Abdul Karim Madidis. Petitioner was subsequently stabbed by Madidis, resulting in his hospitalization and surgery. Procedural History: Petitioner, assisted by his father, filed a complaint for damages against Abdul Karim Madidis and Araneta University, impleading the university based on Article 2180 of the Civil Code. The university filed a Motion to Dismiss, arguing that Article 2180 applies only to vocational schools, not academic institutions, and that the university itself is not liable as the provision speaks only of teachers or heads. The respondent court granted the motion to dismiss, and a subsequent motion for reconsideration was denied. The Petition: Petitioner filed a Petition for certiorari, praying for the setting aside of the orders dismissing the complaint against the respondent school.
Issue(s)
Whether the penultimate paragraph of Article 2180 of the Civil Code is applicable to academic institutions, specifically concerning the liability of the university itself, as distinguished from its teachers or heads. Whether the university itself, as an entity distinct from its teachers or heads, is liable under Article 2180 of the Civil Code.
Ruling
The petition is dismissed for lack of merit. The Court found no necessity to discuss the applicability of Article 2180 to educational institutions not of arts and trades, as the core issue was the liability of the university itself, which the Court found to be negative. The provision explicitly speaks only of 'teachers or heads.'
Ratio Decidendi
On the applicability of Article 2180 to academic institutions and the liability of the university itself: The Court found it unnecessary to delve into the broader question of whether Article 2180 applies to academic institutions in general. The focus of the petition was on the specific liability of the university as an entity, rather than its teachers or heads. The Court's decision hinges on a narrower interpretation of the provision's scope of liability. The Court ruled in the negative regarding the university's liability under Article 2180. On the liability of the university itself: The reasoning is that the penultimate paragraph of Article 2180 of the Civil Code clearly and exclusively speaks of the liability of "teachers or heads of establishments of arts and trades." The provision does not extend this liability to the institution or university itself. Therefore, the university, as an entity distinct from its teachers or heads, cannot be held liable under this specific provision for damages caused by its students. The language of the law is precise and limits the responsibility to the individuals directly supervising the students.
Main Doctrine
The penultimate paragraph of Article 2180 of the Civil Code, which imposes liability on teachers or heads of establishments for damages caused by their pupils and students or apprentices while in their custody, applies only to vocational schools and not to academic institutions. Furthermore, the liability under this provision is specifically imposed on the teachers or heads, not on the university itself.