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Digest on Amadora vs CA

The case involves the fatal shooting of Alfredo Amadora by a classmate at Colegio de San Jose-Recoletos, leading his parents to sue the school and its officials for damages. The Supreme Court ruled that Article 2180 of the Civil Code applies to all schools, clarifying that liability depends on the direct supervision of the offending student, which was not established in this case. Ultimately, the Court found none of the defendants liable for Amadora's death as they were not in direct control or negligent regarding the incident.

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3 views1 page

Digest on Amadora vs CA

The case involves the fatal shooting of Alfredo Amadora by a classmate at Colegio de San Jose-Recoletos, leading his parents to sue the school and its officials for damages. The Supreme Court ruled that Article 2180 of the Civil Code applies to all schools, clarifying that liability depends on the direct supervision of the offending student, which was not established in this case. Ultimately, the Court found none of the defendants liable for Amadora's death as they were not in direct control or negligent regarding the incident.

Uploaded by

Erika Reyes
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as PDF, TXT or read online on Scribd
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Amadora vs CA, GR L-47745, April 15, 1988

Facts: On April 13, 1972, Alfredo Amadora, a 17-year-old student of Colegio de San
Jose-Recoletos, was fatally shot by a classmate, Pablito Daffon, in the school auditorium.
The incident occurred a few days before scheduled commencement exercises. Alfredo's
parents filed a civil action for damages under Article 2180 of the Civil Code against the
school, its rector, the high school principal, the dean of boys, the physics teacher, Daffon,
and two other students. The complaint against the students was later dropped.

The Court of First Instance of Cebu held the remaining defendants (the school and its
officials) liable to the parents for damages. However, on appeal, the Court of Appeals
reversed this decision and completely absolved all defendants. The appellate court found
that Article 2180 was not applicable because the Colegio de San Jose-Recoletos was an
academic institution and not a school of arts and trades, and that the students were not in
the custody of the school at the time of the incident as the semester had ended.

Issue: Whether Article 2180 of the Civil Code, concerning the liability of teachers and
heads of establishments of arts and trades for damages caused by their students, applies to
academic institutions and their personnel for torts committed by students while
allegedly in their custody.

Ruling: The Supreme Court ruled that Article 2180 applies to all schools, academic as
well as non-academic. The Court clarified that in academic schools, the teacher in
charge of the student shall be held responsible for the tort, while in establishments of
arts and trades, it is the head who is liable. The phrase "so long as they remain in their
custody" means that the student is under the control and influence of the school
authorities and within its premises for a legitimate purpose, even if the semester has
ended or classes have not yet begun. Liability attaches to the teacher designated to
exercise supervision over the student in a specific class or section.

Applying this interpretation to the case, the Court found that Alfredo Amadora was still
in the custody of the school authorities when he was shot, as he was on the school
premises for a legitimate purpose. However, the rector, principal, and dean of boys could
not be held liable because none of them was the teacher-in-charge of the offending
student; their authority was general, not direct control over particular classes or sections.
The physics teacher was also not shown to be negligent or the teacher-in-charge of the
killer. The Court reiterated that the school itself is not directly liable under Article
2180, but could potentially be held liable under the principle of respondeat superior if its
head or teachers were found negligent. Since none of the individual respondents were
found to be the teacher-in-charge of the killer or negligent in a manner directly linked to
the shooting, the Court ultimately found none of the respondents liable for Alfredo's
death.

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