St. Mary’s Academy v. Carpitanos

 St. Mary’s Academy v. Carpitanos, 

G.R. No. 143363, 

February 6, 2002

DOCTRINE: “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.”’

FACTS:

St. Mary’s Academy, Dipolog City, was conducting an enrollment drive from

February 13-20, 1995. A facet of the enrollment campaign was visitation of schools where

prospective enrollees were studying. As a student of St. Mary’s, Sherwin Carpitanos

joined the campaign. However, on the day of the campaign, he was riding with other high

school students the Mitsubishi jeep of defendant Vivencio Villanueva. On the way to

Larayan Elementary School, the jeep was driven by James Daniel II, who was then 15

years old. James allegedly drove in a reckless manner and resulted to the jeep turned

turtle. Sherwin Carpitanos died from the accident.

Spouses Carpitanos filed a case against James Daniel II (a minor) and his parents.

They also filed a case against the owner of the vehicle Vivencio Villanueva and St. Mary’s

Academy before the Regional Trial Court. The trial court rendered decision finding St.

Mary liable for negligence as having special parental authority on the students whether

inside or outside school pursuant to Article 218 and 219 of the Family Code.

St. Mary appealed to CA but it only reduced damages to be paid.

ISSUES:

Whether or not CA erred in holding petitioner liable for damages for the death of

Sherwin Carpitanos?

HELD:

No. St. Mary is not liable for the death of Sherwin Carpitanos.

The Court of Appeals held petitioner St. Mary's Academy liable for the death of

Sherwin Carpitanos under Articles 218 and 219 of the Family Code, pointing out that

petitioner was negligent in allowing a minor to drive and in not having a teacher

accompany the minor students in the jeep.

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.

“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. Respondents Daniel spouses and

Villanueva admitted that the immediate cause of the accident was not the negligence of

petitioner or the reckless driving of James Daniel II, but the detachment of the steering

wheel guide of the jeep. 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 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 emancipated 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.

Hence, liability for the accident, whether caused by the negligence of the minor

driver or mechanical detachment of the steering wheel guide of the jeep, must be pinned

on the minor's parents primarily. The negligence of petitioner St. Mary's Academy was

only a remote cause of the accident. Between the remote cause and the injury, there

intervened the negligence of the minor's parents or the detachment of the steering wheel

guide of the jeep.

"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."

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.