In Mother Goose Special School System, Inc. v. Spouses Palaganas (G.R. No. 267331, 20 January 2025), a grade school student was punched several times by his classmates. The student reported the incident to the teacher, who did nothing. The student sustained injuries. Several letters and complaints were sent to the school by the parent of said student, but they were ignored.
It was found that the school miserably failed to prove that it complied with its obligation to provide the said student with an atmosphere that promotes learning. Based on the evidence, the school was ill-equipped at identifying and addressing bullying. Based on evidence, it was found that the teachers of Mother Goose were not trained to detect bullying, and they were merely given instructions on how to discipline the same. More, it does not even appear that it has an employee who can properly address the adverse effects of bullying on the bully, the victim, and their families. T
The school’s lack of capacity to detect and address bullying was made apparent by how it negligently handled the incident. When the Teacher found out about the incident, the main perpetrator, was unscathed. Worse, not one of the school’s employees informed the parents of the incident. They only learned about the incident when one of the erring student’s mother called to apologize.
The school’s liability arises from the breach of its contractual obligation as an educational institution (culpa contractual) to provide and maintain a safe learning environment for its students, and not from quasi-delict (culpa aquiliana).