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Incidentally, there was no question that the registered owner of the vehicle
Amadora vs. CA was respondent Villanueva for he even admitted this fact. The Court has held that
the registered owner of any vehicle, even if not used for public service, would
St. Mary’s Academy v. Carpitanos primarily be responsible to the public or to 3rd persons for injuries caused the latter
Petition for review on certiorari of a decision of CA. 2002 while the vehicle was being driven on the highways or streets.

FACTS: In Feb 1995, defendant-appellant St Mary’s Academy of Dipolog City It is not the schools but the registered owned of the vehicle who shall be held
conducted an enrollment drive for the SY 1995-96. Part of the campaign was the responsible for damages for the death of Sherwin Carpitanos.
visitation of schools from where prospective enrollees were studying.
HELD: Judgment reversed. Case remanded to TC for determination of liability of
A student of that school and part of the campaign, Sherwin Carpitanos along w/ defendants excluding St Mary’s.
other high school students were riding in a Mitsubishi jeep driven by James Daniel
II, a 15yr old student of the same school. En route to Larayan Elem School, it was Bonifacia P. VANCIL, petitioner vs. Helen G. BELMES, respondent
alleged that minor James drove the jeep in a reckless manner and as a result the Petition for review on certiorari of CA decision [June 19, 2001]
“jeep turned turtle”.
Sherwin Carpitanos died as a result of the injuries he sustained from the accident.  Bonifacia Vancil is the mom of Reeder C. Vancil, a US Navy serviceman who
died in US in 1986. Reeder had a common-law wife, Helen Belmes, w/whom he
RTC held St Mary’s liable for indemnification for loss of Sherwin’s life, actual had 2 kids, Valerie & Vincent.
damages for burial and so-related expenses, atty’s fees and moral damages. CA  Bonifacia instituted guardianship proceedings over person & properties of
affirmed decision but absolved from any liability the driver-minor James and jeep’s Valerie (6 yrs old) & Vincent (2 yrs old). Estate consists of proceeds from dad’s
owner Vivencio Villanueva. pension benefits worth P100k. RTC Cebu appointed Bonifacia as legal & judicial
St Mary’s appealed. CA reduced actual damages to PhP25K but affirmed the rest of  Natural mother Helen opposed claiming she already filed a similar petition for
its previous decision. School filed MFR but was denied. Hence, this appeal. guardianship. She later on filed a motion for Removal of Guardian &
Appointment of New One claiming that she’s the natural mom in actual custody
ISSUES & RATIO: of & exercising parental authority over children. She further asserted that
1. WON CA erred in holding St Mary’s liable for said death Bonifacia was a resident of Colorado, USA & that she’s a naturalized US citizen.
Yes. CA held school liable under Arts 218 & 219 FC, pointing out that petitioner RTC rejected & denied motion.
was negligent in allowing a minor to drive in the campaign to visit public schools to  CA reversed. FC 225: parents, father or in his absence, mother are considered
solicit enrollment. School was also liable in not having a teacher accompany the as natural guardian of minor children. Revised ROC Rule 93 Sec. 7 confirms
minor students in the jeep. designation of parents as ipso facto guardian of their minor kids w/o need of
court appointment & such can only be transferred to another person for a good
However, for petitioner to be liable, it must be shown that the act or omission reason. CA found no reason why biological mom should be deprived of her legal
considered as negligent was the proximate cause of the injury caused because the right. Affirming RTC would abdicate & violate the very basic fundamental tenets
negligence, must have a causal connection to the accident. in civil law & the constitution on family solidarity.
 Bonifacia claims that she should be appointed as the guardian based on the
But resp-sps Daniel and Villanueva admitted that the immediate cause of the undisputed proof that Helen’s live-in partner has raped Valerie 7x while under
accident was not the negligence of the school or the reckless driving of James Helen’s custody.
Daniel II, but the detachment of the steering wheel guide of the jeep. This was
confirmed by the testimony of the traffic investigator who instituted a report of the Issue: WON Bonifacia should be appointed as the guardian.
accident. Held: NO. CA affirmed.
Hence, reliance on Art 219 FC that “those given the authority and responsibility 1. Case is moot WRT Valerie since she alredy turned 18 on Sept. 2, 1998. Only
under Art 218 shall be principally and solidarily liable for damages caused by acts or thing in dispute is guardianship of Vincent.
omissions of the unemancipated minor” was unfounded. 2. FC 211: Father & mother shall jointly exercise parental authority over their
common children. Father’s decision shall prevail in cases of disagreement unless
Liability, whether caused by the negligence of the minor-driver or mechanical there’s a judicial order to the contrary. Thus, Helen, being the natural mom of
detachment of the jeep’s steering wheel guide, must be pinned on the minor’s Vincent has the natural & legal rt to his custody. Such rt is inherent & not
parents primarily. The negligence of St Mary’s was only a remote cause of the created by state/decision of courts but derives from nature of parental
accident, an event that the school had no control over. relationship (Sagala-Eslao vs. CA).
3. FC 214 allows substitute parental authority of surviving grandparent only in
2. WON CA erred in affirming the award of moral damages against the school case of death, absence or unsuitability of parents. Helen is very much alive &
has continuously exercised parental authority over Vincent. Helen’s unfitness
was only asserted WRT Valerie & since she’s already of major age, such cannot
♦ Court of Appeals reversed the decision of the trial court. The court cited
be appreciated anymore. the case of Ortanez vs. Dela Cruz which held that A father or mother acting
4. Even if Helen were unfit, Bonifacia still won’t qualify considering that she’s a US as legal administrator of the property of the child under parental authority
citizen & resident. She won’t be able to perform the responsibilities & cannot, therefore, dispose of the child's property without judicial authority
obligations required of a guardian. Most probably she’ll just delegate those if it is worth more than P2,000.00, notwithstanding the bond that he has
duties to another person who might not be qualified. She’s been out of the filed for the protection of the child's property. But when the value of such
country since 1987 and considering that she’s old & was previously convicted of property is less than P2,000.00, the permission of the court for its
libel, it’s not likely that she’ll come back here to fulfill her duties. Besides, only alienation or disposition may be dispensed with. The father or mother, as
2 yrs are left for her to exercise guardianship over child. the case may be, is allowed by law to alienate or dispose of the same
5. Guerrero vs. Teran: True that law does not require courts to only appoint freely, subject only to the restrictions imposed by the scruples of
residents as guardians but court should not appoint guardians who are not w/in conscience
our courts’ jurisdiction for it will be difficult to protect the wards in such
instances. Issue: WON the judicial approval is necessary for the sale of the minors’ property by
their mother. YES
Vitug, concurring: Law & jurisprudence recognizes deep ties that bind parent &
child. Parents are placed 1st in rank in matters of parental authority. Child’s Ratio:
legitimacy doesn’t affect the order of priority in exercise of parental authority. FC ♦ Art 320 of the new civil code: The father, or in his absence the mother, is
176 states that illegitimate child shall be under parental authority of mom who the legal administrator of the property pertaining to the child under
should also be entitled to custody of child. parental authority. If the property is worth more than two thousand pesos,
the father or mother shall give a bond subject to the approval of the Court
Libi vs. IAC (separate) of First Instance.
♦ Under article 320 a parent acts merely as the legal administrator of the
Lindain vs. Court of Appeals [August 20, 1992] property of the minor children and does not have the power to dispose of
Petition for review on certiorari of the decision of the Court of Appeals or alienate, the property of the children, without judicial approval.
♦ General Powers and Duties of Executors and Administrators are only
Facts: powers of possession and management. Her power to sell, mortgage,
encumber or otherwise dispose of the property of her minor children must
♦ Petition for review on certiorari of the decision dated August 8, 1990 of the proceed from the court, as provided in Rule 89 which requires court
Court of Appeals which dismissed the complaint for annulment of a sale of authority and approval.
registered land, thereby reversing the decision of the Regional Trial Court
of San Jose City ♦ Visaya vs. Suguitan – under article 320 the mother as legal administrator
♦ When Elena, Oscar, Celia and Teresita (Plaintiffs) were still minors they had no power to compromise their claims, for compromise has always
were already the registered owners of a parcel of land covered by Transfer deemed equivalent to alienation. The Court's approval is necessary in
Certificate of Title No. NT-63540 compromises entered into by guardians, parents, absentee's
♦ November 7, 1966 – their mother, Dolores Luluquisin, then already a representatives and administrators or executors of decedent's estates.
widow and acting as guardian of her minor children, sold the land for ♦ Badillo vs. Ferrer - Surviving widow has no authority or has acted beyond
P2,000 under a Deed of Absolute Sale of Registered Land to the spouses her powers in conveying to the vendees the undivided share of her minor
Apolonia Valiente and Federico Ila (Defendants). The Deed of Absolute Sale children in the property, as her powers as the natural guardian covers only
was registered in the office of the Register of Deeds for the Province of matters of administration and cannot include the power of disposition, and
Nueva Ecija. TCT No. NT-66311 was issued to the vendees, Apolonia she should have first secured court approval before alienation of the
Valiente and Federico Ila. property.
♦ The vendee admitted that they knew that the property belonged to the ♦ The minors' action for reconveyance has not yet prescribed for "real actions
minors. over immovables prescribe after thirty years" (Art. 1141, Civil Code). Since
♦ Plaintiffs contend, however, that the sale of the lot by their mother to the the sale took place in 1966, the action to recover the property had not yet
defendants is null and void because it was made without judicial authority prescribed when the petitioners sued in 1987.
and/or court approval.
♦ The defendants contend that the sale was valid, as the value of the People vs. Silvano
property was less than P2,000, and, considering the ages of plaintiffs now,
the youngest being 31 years old at the time of the filing of the complaint,
their right to rescind the contract which should have been exercised four
(4) years after reaching the age of majority, has already prescribed.
♦ RTC ruled in favour of the of the plantiffs