Philippine School of Business Administration vs.

CA [205 SCRA 729 GR

No. 84698. February 4, 1942]
Post under case digests, Civil Law at Tuesday, March 20, 2012 Posted by Schizophrenic Mind

Facts: Carlitos Bautista was stabbed while on the second

floor premises of the schools by assailants who were not
members of the schools academic community. This
prompted the parents of the deceased to file a suit in the
RTC of Manila for damages against PSBA and its
corporate officers.
The defendant schools (now petitioner) sought to have the
suit dismissed on the ground of no cause of action and not
within the scope of the provision of Art 2180 since it is an
academic institution. The trial court overruled the
petitioners contention and its decision was later affirmed
by the appellate court.
Issue: Whether the decision of the appellate court
primarily anchored on the law of quasi-delicts is valid.
Held: Although the Supreme Court agreed to the decision
of the Court of Appeals to deny the petition of motion to
dismiss by the PSBA, they do not agree to the premises of
the appellate courts ruling.

Art 2180, in conjunction with Art 2176 of the civil code

establishes the rule of in loco parentis, they can not be
held liable to the acts of Calitos assailants which were not
students of the PSBA and because of the contractual
relationship.
The school and the students, upon registration established
a contract between them, resulting in bilateral obligations.
The institution of learning must provide their students with
an atmosphere that promotes or assists its primary
undertaking of imparting knowledge, and maintain peace
and order within its premises.
The SC dismissed the petition and the case was
remanded to the trail court to determine if the school
neglected its obligation to perform based on the
contractual relation of them and the students.