ST. LUKE’S COLLEGE OF MEDICINE- WILLIAM H.

QUASHA MEMORIAL
FOUNDATION V. SPOUSES MANUEL AND ESMERALDA PEREZ & SPOUSES ERIC
AND JURISITA QUINTOS +
G.R. NO. 222770
SEPTEMBER 28, 2016
PEREZ, J.
Facts:

The petionioner entered into a Memorandum of Intent with the Municipality of Cabiao,
Nueva Ecija for a construction of a community clinic. The said facility consisted of six-bed
medical facility in the ground floor and a residential space for medical staff in the second floor.
St. Luke’s sent four of its medical students including the daughters of the respondents to
complete a four- week clerkship rotation at the clinic, and like the previous batches, they were
housed on the second floor of the clinic.
On February 9, 2010, a fire broke out on the second floor resulting to the death of the
female medical students, including the daughters of the plaintiff- appellants, due to smoke
inhalation resulting “to asphyxia”. The Bureau of Fire Protection (BFP) conducted an
investigation on the incident and certified that the fire was accidental in nature due to unattended
cooking.
Respondents had their doubts and sought the help of the National Bureau of Investigation
(NBI) and the latter declared that the construction of the Cabiao Community Clinic building was
a violation of the provisions of the Revised Fire Code of the Philippines.
Respondents then filed a complaint for damages against petitioner claiming that their
negligence caused the deaths of respondents’ daughters.
The Regional Trial Court(RTC) dismissed the complaint for lack of merit but upon
appeal, the Court of Appeals (CA) reversed the RTC decision and remanded the case to the RTC
for reception of evidence on the amount of damages to be awarded.
Issue:
Whether or not the petitioner is liable for the deaths of medical students for being
negligent.
Ruling:
Yes. The petitioners and the victims are bound by the enrolment contracts. Institutions of
learning have the “built-in” obligation of providing a conducive atmosphere for learning where
there are no constant threats to life and limb, and where peace and order are maintained. The
law, recognizing the obligatory force of contracts, will not permit a party to be set free from
liability of any kind of misperformance of the contractual undertaking or a contravention of the
tenor thereof.
In the case at bar, the Cabiao Community Clinic is to be considered as part of the campus
premises of St. Luke’s. As such, it was mandatory upon petitioners to ensure that the said clinic
was conducive for learning, that it has no constant threats to life and limb and that peace and
order was maintained thereat. Petitioner failed to comply with this obligation. It failed to take the
necessary precautions to guard their students against foreseeable harm, it remiss in inspecting the
premises of the Cabiao Community Clinic and in ensuring that the necessary permits were in
order. These precautions could have minimized the risk to the safety of the victims. Hence,
petitioner is liable for being negligent.