Gil Apolinario v. Heirs of Francisco de Los Santos

Summary

This case involves vicarious liability for negligence causing death. On July 4, 1998, school principal Gil Apolinario instructed 16-year-old student Rico to cut a banana plant beside a highway during a school activity. The plant fell and fatally struck motorcyclist Francisco De Los Santos. The victim's heirs sued for damages. The Supreme Court affirmed Apolinario's vicarious liability under quasi-delict provisions, finding that teachers have special parental authority over students and are liable for their tortious acts while in custody. However, the Court deleted the award for loss of earning capacity due to insufficient evidence and improper judicial notice, instead increasing temperate damages. The decision clarifies the scope of vicarious liability for educational institutions and the evidentiary requirements for damages claims, particularly regarding loss of earning capacity awards.