TITLE: St. Mary’s Academy vs. Carpitanos, G.R. No.

143363, February 6, 2002

TOPIC: Sources of Obligations

PRINCIPLE: Legal obligations arising from law are not presumed. To be demandable, they
must be clearly set forth in the law. In this case, the respondents failed to show that the
negligence of petitioner was the proximate cause of the death of the victim.

FACTS:

St. Mary’s Academy conducted an enrollment drive in Dipolog City for the upcoming school year
199-1996. Part of the enrollment campaign is to inspect the schools where prospective
enrollees were currently enrolled.

Sherwin Carpitanos was part of the enrollment campaign of the school. He, together with the
other high school students rode a Mitsubishi jeep on their way to a school in Dapitan City. The
vehicle was driven by a 15-year old schoolmate who drove in a reckless manner which led to an
accident. Unfortunately, Sherwin died due to the injuries that he sustained. The victim’s parents
filed a case for damages against the 15-year old driver, his parents, the vehicle owner and
school.

ISSUE: Whether or not the petitioner St. Mary’s Academy is liable for damages for the death of
Sherwin Carpitanos.

RULING:

No. The Court held that the act or omission to be considered negligent must be the proximate
cause of the injury caused thus, negligence needs to have a causal connection to the accident.
It must be direct and natural sequence of events, unbroken by any efficient intervening causes.
The parents of the victim failed to show such negligence on the part of the petitioner. The
spouses Villanueva admitted that the immediate cause of the accident was not the reckless
driving of James but the detachment of the steering wheel guide of the jeep. 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. It is not the school, but the registered owner of the
vehicle who shall be held responsible for damages for the death of Sherwin.