St. Joseph’s College v. Miranda

St. Joseph’s College v. Miranda, 

G.R. No. 182353, 

June 29, 2010

DOCTRINE: Petitioner school is liable for the wrongful acts of the teachers and

employees since it had full information on the nature of dangerous science experiments

but did not take affirmative steps to avoid injury to the students.


On Nov. 17, 1994, 130PM, inside St. Joseph College’s (SJC’s) premises, the

class to which respondent Jayson Val Miranda (12yo) belonged was conducting a science

experiment about fusion of Sulphur powder and iron fillings under the tutelage of petitioner

Rosalinda Tabugo, being the subject teacher and employee of SJC. Jayson’s class

adviser is Estefania Abdan. While the class was doing the experiment, Tabugo left her

class. Jayson, assistant leader of one of the class groups, checked the result of the

experiment by looking into the test tube with magnifying glass. The tube was being held

by one of his group mates who moved it close towards the eye of Jayson. At that instance,

the compound in the test tube spurted out and several particles hit Jayson’s eye, which

was thus chemically burned, particularly his left eye. He had to undergo surgery and

spend for medication. Upon learning of the incident, Jayson’s mother, who was working

abroad, had to rush back home for which she spent P36k and had to forego her 1 month

salary of P40k.

Jayson sent a demand letter to petitioners SJC, Sr. Josephini Ambatali, and Tabugo for

payment of his medical expenses which petitioners failed to heed. Thus, Jayson filed a

complaint for damages against petitioners.

Petitioners allege that before the experiment, Jayson and the class were given strict

instructions to follow the written procedure for the experiment and not look into the test

tube until the heated compound had cooled off. Jayson, a person of sufficient age and

discretion and capable of understanding English, violated such instructions. Jayson’s

father Rodolfo had requested SJC to advance P26k for medical expenses to prevent

delay in Jayson’s discharge from the hospital, to which request SJC acceded. But then,

Jayson’s parents, thru counsel, sent SJC a demand letter demanding that SJC shoulder

all medical expenses of Jayson. SJC did not accede to this. RTC ruled that petitioners

were jointly and solidarily liable to Jayson for damages. CA affirmed. Hence this petition.


Whether or not St. Joseph’s College is liable.


YES. CA findings as approved by SC- All of petitioners are equally liable for

negligence since all of them are responsible for exercising reasonable prudence and

foresight to prevent injuries to the students. Tabugo was not inside the classroom when

the accident happened. Estefania Abdan, the adviser (*who is not a party in this case), is

equally at fault because she exercised control and supervision over Tabugo and the

students. Petitioner Sr. Josephini Ambatali is also culpable under the doctrine of

command responsibility since the other individual petitioners were under her direct control

and supervision. The negligent acts of the other petitioners were done within the scope

of their assigned tasks.

SJC cannot raise the defense of diligence of a gff since it was guilty of inexcusable laxity

in the supervision of its teachers (Despite a rigid screening process for hiring). Petitioner

school is liable for the wrongful acts of the teachers and employees since it had full

information on the nature of dangerous science experiments but did not take affirmative

steps to avoid injury to the students.

Petitioners claim that Tabugo instructed her students, including Jayson, at the start of the

experiment, not to look into the test tube before the compound had cooled off.

But the proximate cause of Jayson’s injury was the failure of petitioners to prevent the

foreseeable mishap. Art. 218 of the Family Code and Art. 2180 of NCC bestows special

parental authority on the following:

Art. 218. The school, its administrators and teachers, or the individual, entity or institution

engaged in child care shall have special parental authority and responsibility over the

minor child while under their supervision, instruction or custody.

Authority and responsibility shall apply to all authorized activities whether inside or outside

the premises of the school, entity or institution.

Art. 2180. The obligation imposed by Article 2176 is demandable not only for one's own

acts or omissions, but also for those of persons for whom one is responsible.

xxx xxx xxx

Lastly, teachers or heads of establishments of arts and trades shall be liable for damages

caused by their pupils and students or apprentices, so long as they remain in their


SC also affirmed the lower courts’ rulings that Jayson was guilty of contributory

negligence. The proximate cause was the explosion of the heated compound. The

negligence of Tabugo in not making sure that the experiment was correctly conducted

was the proximate cause why the heated compound exploded and injured Jayson.

But Jayson is partly responsible, thus he is not entitled to recover damages in full.

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