St. Mary's Academy vs Carpetanos

St. Mary’s Academy vs. Carpetanos

GR No. 143363, February 6, 2002

FACTS:

Herein petitioner, conducted an enrollment drive for the school year 1995-1996 They visited schools from where prospective enrollees were studying.  Sherwin Carpitanos joined the campaign.  Along with the other high school students, they rode a Mitsubishi jeep owned by Vivencio Villanueva on their way to Larayan Elementary School. Such jeep was driven by James Daniel II, a 15 year old student of the same school.  It was alleged that he drove the jeep in a reckless manner which resulted for it to turned turtle.  Sherwin died due to this accident. 

ISSUE: WON petitioner should be held liable for the damages.

HELD:

CA held petitioner liable for the death of Sherwin under Article 218 and 219 of the Family Code where it was pointed that they were negligent in allowing a minor to drive and not having a teacher accompany the minor students in the jeep.  However, for them to be held liable, the act or omission to be considered negligent must be the proximate cause of the injury caused thus, negligence needs to have a causal connection to the accident.  It must be direct and natural sequence of events, unbroken by any efficient intervening causes.  The parents of the victim failed to show such negligence on the part of the petitioner.  The spouses Villanueva admitted that the immediate cause of the accident was not the reckless driving of James but the detachment of the steering wheel guide of the jeep.  Futhermore, there was no evidence that petitioner allowed the minor to drive the jeep of Villanueva.  The mechanical defect was an event over which the school has no control hence they may not be held liable for the death resulting from such accident.

The registered owner of any vehicle, even if not used for public service, would primarily be responsible to the public or to 3^rd persons for injuries caused while it is being driven on the road.  It is not the school, but the registered owner of the vehicle who shall be held responsible for damages for the death of Sherwin.  Case was remanded to the trial court for determination of the liability of the defendants excluding herein petitioner.