St. Mary’s Academy v.

Carpitanos
GR. No. 143363

Doctrine: DAMAGES; REGISTERED OWNER OF VEHICLE PRIMARILY RESPONSIBLE FOR INJURIES

CAUSED TO THE PUBLIC OR TO THIRD PERSONS WHILE VEHICLE WAS BEING DRIVEN ON THE
HIGHWAYS OR STREETS. — We have held that the registered owner of any vehicle, even if not
used for public service, would primarily be responsible to the public or to third persons for
injuries caused the latter while the vehicle was being driven on the highways or streets. Hence,
with the overwhelming evidence presented by petitioner and the respondent Daniel spouses
that the accident occurred because of the detachment of the steering wheel guide of the jeep,
it is not the school, but the registered owner of the vehicle who shall be held responsible for
damages for the death of Sherwin Carpitanos.

Facts: St. Marys academy conducted an enrollment drive for school year 1995- 1996. Sherwin
Carpitanos was a student of St. Mary’s Academy campaign group for the school’s “Recruitment
drive”, wherein they go to other schools to recruit new students. Sherwin was riding, with other
highschool students, a Mitsubishi jeep owned by Vivencio Villanueva, on their way to Larayan
Elementary School, Dapitan City. Such jeepney was driven by a 15 year old James Daniel II,
whom allegedly drove recklessly. They died in an accident caused by the Detachment of the
steering wheel guide of the jeepney. Sherwin Capitanos fied as a result from injuries sustained
in the Accident. The RTC ordered St. Marys Academy to pay William Carpitanos and Luisa
Carpitanos Indemnity for the loss of life of Sherwin, Actual Damages for burial and related
expenses, Atty’s fee’s and Moral Damages. Parents of James Daniel II are only subsidiary liable
to the damages. James Daniel II is absolved since he was a minor. Vivencio Villanueva is
ABSOLVED. St. Mary’s appealed to the CA. CA affirmed a quo, in toto but reduced actual
damages. CA held St. Marys academy lable for the death under article 218 (Special parenthal
authority od schools, which applies to field trips, excursions, and other affairs) and 219 (If a
person in custody is a minor, a person exercising special parental authority are principally and
solidarily liable for damages by act or omission of minor), pointing out that they were negligent
in allowing a minor to rive and in not having a teacher accompany the minor students in the
jeep. St Mary’s a motion of reconsideration which was denied.

Issue: Whether or not the School is liable for the death of Sherwin.

Held:
The SC REVERSED and set aside decision and remanded to the trial court for
determination of liability of defendants excluding St. Mary’s Academy.

The School is not Liable. For Petitioner to be liable under article 218 and 219 There
MUST be finding of proximate cause of the injury caused, which respondents failed to show.
VILLANUEVA ADMITED that the PROXIMATE CAUSE WAS THE DETACHMENT OF THE STEERING
WHEEL GUIDE, a mechanical defect, this was affirmed by a traffic investigator. Futhermore,
there was no evidence that petitioner, allowed the minor to drive the jeep of Villanueva, It was
Ched Villanueva, the grandson of Vivencio, was the one who allowed the minor to drive. 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.

Villanueva was the owner of the Vehicle, he never denied and in fact admitted this fact. We
have held that the registered owner of any vehicle, even if not used for public service, would
primarily be responsible to the public or to third persons for injuries caused the latter while the
vehicle was being driven on the highways or streets." Hence, with the overwhelming evidence
presented by petitioner and the respondent Daniel spouses that the accident occurred because
of the detachment of the steering wheel guide of the jeep, it is not the school, but the
registered owner of the vehicle who shall be held responsible for damages for the death of
Sherwin Carpitanos.