**St. Joseph’s College v. Miranda**
## Facts:
On November 17, 1994, at around 1:30 PM, inside St. Joseph’s College (SJC) in Quezon City, Jayson Miranda, a grade six student, along with his classmates, was conducting a science experiment on the fusion of sulfur powder and iron fillings under the supervision of their subject teacher, Rosalinda Tabugo. Tabugo, however, left the class unsupervised. During the experiment, Miranda looked into a test tube with a magnifying glass and the compound therein spurted out, causing chemical burns to his eye and other parts of his classmates’ bodies. This led to Miranda undergoing surgery and incurring significant medical expenses.
Upon the incident, Miranda’s mother, who was working abroad, returned to the Philippines and incurred expenses amounting to P36,070 for airfare and foregone salary approximating P40,000 to attend to her son’s condition. Despite demands for compensation sent to SJC for medical expenses and other damages, the school did not heed the request. Consequently, Miranda’s father, on behalf of his son, filed a complaint for damages with the RTC of Quezon City.
The RTC ruled in favor of Miranda, holding the appellants jointly and solidarily liable for:
1. Actual damages amounting to P77,338.25 with a legal compensation deduction of P26,176.36 previously advanced by SJC.
2. Mitigated moral damages of P50,000.
3. Attorney’s fees of P30,000.
4. Costs of the suit.
The decision was subsequently appealed to the Court of Appeals (CA), which affirmed the RTC’s ruling. SJC then petitioned the Supreme Court for a review on certiorari.
## Issues:
1. Whether the proximate cause of Jayson Miranda’s injury was his own act of looking into the test tube against instructions.
2. Whether Miranda’s contributory negligence absolves the petitioners from liability.
3. Whether the awards for actual, moral damages, and attorney’s fees, as determined by the lower court, were justified.
## Court’s Decision:
**Proximate Cause and Contributory Negligence:**
– The Supreme Court held that the proximate cause of the injury was the explosion of the chemicals during the experiment, not Miranda’s act of peeking into the test tube.
– The court emphasized that the negligence of Tabugo and other school officials was manifest. Miranda’s actions, while contributory, did not absolve the school and its personnel from their responsibility because they failed negligibly to predict and prevent a foreseeable harm.
– The constant instructions by Tabugo and the established protocol were found insufficient to alter the fact that the experiment posed a foreseeable risk, and SJC failed to implement adequate safety measures.
**Damages:**
– The court affirmed the award for actual damages appropriate to the expenses Miranda’s family incurred due to the injury.
– Moral damages were deemed reasonable due to the emotional distress suffered by Miranda and his family.
– The attorney’s fees award was also found justified given the protracted nature of the litigation.
**Doctrine:**
– The court reiterated the responsibility of educational institutions and their personnel over the welfare of their students during educational activities under the principle of **”in loco parentis”**.
– Cited **Articles 218 and 2180 of the Family Code** and **Civil Code** emphasizing the special parental authority and liability of schools for the acts of their students while under supervision.
– The principle of **proximate cause** was highlighted — liability for negligence depends on the direct causal connection between the negligent act and the resulting harm.
## Class Notes:
– **Negligence:** Schools have a heightened duty of care to prevent foreseeable risks in student activities.
– **Proximate Cause:** Liability is determined by whether the negligent act was the immediate cause of the injury.
– **Articles 218 and 2180 of the Family Code:** Schools have special parental authority and are responsible for damages caused by their pupils.
– **Contributory Negligence:** Does not necessarily absolve a school from liability if the school’s broader duty of care intervenes.
**Statutory Provisions:**
– **Article 218 of the Family Code:** “The school, its administrators and teachers shall have special parental authority and responsibility over the minor child while under their supervision, instruction, or custody.”
– **Article 2180 of the Civil Code:** provides liability of school heads and teachers for the actions of pupils while in their custody.
**Case Principle:**
– Institutions must institute and enforce comprehensive safety measures for student activities, significantly when the activities involve inherent risks.
## Historical Background:
The context of the case reflects the amplified legal standards on institutions’ duty of care tipped by emerging jurisprudence emphasizing student welfare. Following significant legal precedents and evolving concepts of **educational liability**, this case serves as a crucial reference for the responsibilities of educational institutions under Philippine law.
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