Philippine School of Business Administration v. Court of Appeals

Summary

This case arose from the stabbing death of PSBA student Carlitos Bautista by outsiders on school premises. His parents sued the school and its officers for damages, alleging negligence in security. The defendants sought dismissal, arguing that schools are not liable under Article 2180 of the Civil Code when harm is caused by non-students. The Supreme Court denied the petition but rejected the Court of Appeals' reliance on quasi-delictual liability. Instead, the SC ruled that liability should be based on the contractual relationship between school and student, with schools having an implicit obligation to provide a safe learning environment. The Court distinguished between quasi-delictual liability (which requires student-perpetrators) and contractual liability (which can exist regardless of who causes the harm). The case was remanded for trial on the merits to determine if the school breached its contractual duty through negligence in providing adequate security measures.