PSBA v. CA (G.R. No. 84698)

Facts:

Private respondents sought to adjudge petitioner PSBA and its officers liable for the death of Carlitos Bautista, a third year commerce student who was stabbed while on the premises of PSBA by elements from outside the school. Private respondents are suing under the law on quasi-delicts alleging the school and its officers’ negligence, recklessness and lack of safety precautions before, during, and after the attack on the victim. Petitioners moved to dismiss the suit but were denied by the trial court. CA affirmed.

Issue:

Whether or not PSBA may be held liable under quasi-delicts.

Ruling: NO.

Because the circumstances of the present case evince a contractual relation between the PSBA and Carlitos Bautista, the rules on quasi-delict do not really govern. A perusal of Article 2176 shows that obligations arising from quasi-delicts or tort, also known as extra-contractual obligations, arise only between parties not otherwise bound by contract, whether express or implied.

When an academic institution accepts students for enrollment, there is established a contract between them, resulting in bilateral obligations which both parties are bound to comply with. For its part, the school undertakes to provide the student with an education that would presumably suffice to equip him with the necessary tools and skills to pursue higher education or a profession. On the other hand, the student covenants to abide by the school’s academic requirements and observe its rules and regulations. 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.

In the circumstances obtaining in the case at bar, however, there is, as yet, no finding that the contract between the school and Bautista had been breached thru the former’s negligence in providing proper security measures. This would be for the trial court to determine. And, even if there be a finding of negligence, the same could give rise generally to a breach of contractual obligation only.

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