Agapito Fuellas v. Cadano

Summary

This case involved the civil liability of a father for serious physical injuries caused by his 13-year-old son to a classmate. Rico Fuellas deliberately pushed Pepito Cadano during a school altercation, causing complete fracture of both bones in Pepito's right forearm. The central legal issue was whether Article 2180 of the Civil Code, which holds parents liable for damages caused by minor children, applies when the minor acts with criminal intent rather than mere negligence. The Supreme Court affirmed the lower courts' finding of liability, ruling that parental responsibility under Article 2180 is based on the pater familias relationship and the father's presumed negligence in supervision, regardless of whether the minor's act was deliberate or negligent. The Court emphasized that civil liability under quasi-delict provisions is separate and independent from criminal liability, rejecting the argument that only the Revised Penal Code's subsidiary liability provisions should apply to deliberate criminal acts by minors.