Damages based on breach of contract

After a punching incident in school, the parents of the aggrieved student sued the school and the teacher in charge. The trial court found both liable. On appeal, though, the Court of Appeals modified the ruling, making the school solely liable while absolving the teacher.

This made the school pursue the issue in the Supreme Court. It argued that since its employee was no longer liable, then it should likewise be exonerated. The school based this on the principle of vicarious liability under Article 2180 of the Civil Code.

The Supreme Court, however, denied its appeal and ruled:

“In this case, X School’s liability arises from the breach of its contractual obligation as an educational institution (culpa contractual) to provide and maintain a safe learning environment for its students, and not from quasi-delict (culpa aquiliana). Jurisprudence has consistently differentiated culpa contractual from culpa aquiliana.”

“Culpa contractual is the fault or negligence in the performance of a pre­-existing obligation. The mere proof of the existence of the contract and the failure of its compliance justify, prima facie, a corresponding right of relief. On the other hand, culpa aquiliana is the wrongful or negligent act or omission that creates a vinculum juris and gives rise to an obligation between two persons not formally bound by any other obligation. It is governed by Article 2176 of the Civil Code.”

“In the landmark case of Philippine School of Business Administration v. CA, the Court eloquently explained the nature of the contractual relationship between the school and its students, resulting in bilateral obligations: When an academic institution accepts students for enrollment, a contract is established between them, resulting in bilateral obligations which both parties are bound to comply with.

“The Court also emphasized that academic institutions have a ‘built-in’ obligation to provide a conducive atmosphere for learning, where there are no constant threats to the life and limbs of the students. Thus, the school must ensure the maintenance of peace and order within the campus.”

“Institutions of learning must also meet the implicit or ‘built-in’ obligation of providing their students with an atmosphere that promotes or assists in attaining its primary undertaking of imparting knowledge. Necessarily, the school must ensure that adequate steps are taken to maintain peace and order within the campus premises and to prevent the breakdown thereof. It is settled that in culpa contractual, the mere proof of the existence of the contract and the failure of its compliance justify, prima facie, a corresponding right of relief.”

“Article 1173 of the Civil Code defines negligence as ‘the omission of that diligence which is required by the nature of the obligation and corresponds with the circumstances of the persons, of the time and of the place.’ In the absence of a stipulated standard of diligence, the diligence of a good father of a family must be observed.”

“Furthermore, negligence becomes gross when there is a ‘want of even slight care and diligence.’ Here, both the RTC and the CA found X School to be grossly negligent in handling the punching incident. The Court agrees.”

“The school then, as an institution, and not its employees could be faulted, primarily with the happening of the incident, or its management after its occurrence. The defendant school failed to exercise the required diligence, prudence, and foresight to avoid the happening of the assault, or to address its happening.

“Since X School’s negligence arises from an existing contractual obligation, its defense that it exercised due diligence in the selection and hiring of employees under Article 2180 of the Civil Code, which is applicable only for quasi-delicts, must fail.”

The quoted portion of the decision is from SC G.R. No. 267331 (20 January 2025). Both the quoted decision and the names of the parties have been redacted.