Aquinas School v. Sps. Jose Inton · G.R. 184202

Petitioner: Aquinas School
Respondent: Sps. Jose Inton
Citation: G.R. No. 184202
Court: Supreme Court
Division: Second Division
Ponente: Abad, J.
Decided: January 26, 2011

Summary

This civil case involved parents suing Aquinas School and religion teacher Sr. Margarita Yamyamin for damages after the teacher physically abused their grade three son Jose Luis in July 1998. The RTC held only Yamyamin liable for damages totaling P60,000. The Court of Appeals reversed, finding both the school and teacher solidarily liable under Article 2180 of the Civil Code, reasoning that an employer-employee relationship existed. The Supreme Court ultimately granted Aquinas School's petition, applying the four-fold test for determining employer-employee relationships and emphasizing the crucial element of control. The Court found that Yamyamin was an outside catechist sent by a religious congregation under an agreement, not a school employee, and that Aquinas had taken reasonable precautionary measures including proper vetting, orientation, and oversight procedures. The decision establishes important precedent regarding vicarious liability of educational institutions for acts of outside religious instructors.

Statutes applied

Civil Code, Art. 2180

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By the Intellegal Editorial Board · January 26, 2011

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