GR No. 143363, 6 February 2002
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. Spouses William Carpitanos and Lucia Carpitanos filed a case against James Daniel II and his parents, James Daniel Sr. and Guada Daniel, the vehicle owner, Vivencio Villanueva and St. Marys Academy
Whether or not petitioner should be held liable for the damages.
No. Considering that the negligence of the minor driver or the detachment of the steering wheel guide of the jeep owned by respondent Villanueva was an event over which petitioner St. Marys Academy had no control, and which was the proximate cause of the accident, petitioner may not be held liable for the death resulting from such accident.
The 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 petitioner to be liable, there must be a finding that the act or omission considered as negligent was the proximate cause of the injury caused because the negligence must have a causal connection to the accident. In order that there may be a recovery for an injury, however, it must be shown that the injury for which recovery is sought must be the legitimate consequence of the wrong done; the connection between the negligence and the injury must be a direct and natural sequence of events, unbroken by intervening efficient causes. In other words, the negligence must be the proximate cause of the injury. For, negligence, no matter in what it consists, cannot create a right of action unless it is the proximate cause of the injury complained of. And the proximate cause of an injury is that cause, which, in natural and continuous sequence, unbroken by any efficient intervening cause, produces the injury, and without which the result would not have occurred.
In this case, the respondents failed to show that the negligence of petitioner was the proximate cause of the death of the victim. Also, there was no evidence that petitioner school allowed the minor to drive the jeep of respondent Vivencio Villanueva. Hence, the registered owner of any vehicle, even if not used for public service, would primarily be responsible to the public or to 3rd 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. Wherefore, the case was remanded to the trial court for determination of the liability of the defendants excluding herein petitioner.
* Case digest by Vera L. Nataa, LLB-1, Andres Bonifacio Law School, SY 2017-2018