Aquinas School vs. Spouses Inton - Case Digest
Aquinas School vs. Spouses Inton - Case Digest
Aquinas School vs. Spouses Inton - Case Digest
FACTS:
Respondent Jose Luis Inton was a grade 3 student at Aquinas School while Respondent
Yamyamin was a religion teacher at said school. Yamyamin caught Luis misbehaving in class
twice, going over to his classmate instead of copying what was written on the blackboard. She
allegedly kicked him in the legs and shoved his head on the classmate's seat.
The parents of Luis filed an action for damages on behalf of their son against Yamyamin and
Aquinas school.
With regard to the action for damages, the Intons sought to recover actual, moral, and
exemplary damages, as well as attorneys fees, for the hurt that Jose Luis and his mother
Victoria suffered. The RTC dismissed Victorias personal claims but ruled in Jose Luis favor,
holding Yamyamin liable to him for moral damages of P25,000.00, exemplary damages of
P25,000.00, and attorneys fees of P10,000.00 plus the costs of suit.
Not satisfied, the Intons elevated the case to the Court of Appeals and they asked it to increase
the award of damages and to hold Aquinas solidarily liable with Yamyamin. Finding that an
employer-employee relation existed between Aquinas and Yamyamin, the CA found them
solidarily liable to Jose Luis.
ISSUE: Whether or not Aquinas is solidarily liable with Yamyamin for the damages awarded to
Jose Luis Inton.
HELD:
No.
In this case, the school directress testified that Aquinas had an agreement with a congregation
of sisters under which, in order to fulfill its ministry, the congregation would send religion
teachers to Aquinas to provide catechesis to its students. Aquinas insists that it was not the
school but Yamyamins religious congregation that chose her for the task of catechizing the
schools grade three students, much like the way bishops designate the catechists who would
teach religion in public schools. Under the circumstances, it was quite evident that Aquinas did
not have control over Yamyamins teaching methods. Consequently, it was error for the CA to
hold Aquinas solidarily liable with Yamyamin.
Of course, Aquinas still had the responsibility of taking steps to ensure that only qualified
outside catechists are allowed to teach its young students. In this regard, it cannot be said that
Aquinas took no steps to avoid the occurrence of improper conduct towards the students by
their religion teacher.
First, Yamyamins transcript of records, certificates, and diplomas showed that she was qualified
to teach religion.
Second, there is no question that Aquinas ascertained that Yamyamin came from a legitimate
religious congregation of sisters and that, given her Christian training, the school had reason to
assume that she would behave properly towards the students.
Third, the school gave Yamyamin a copy of the schools Administrative Faculty Staff Manual that
set the standards for handling students. It also required her to attend a teaching orientation
before she was allowed to teach beginning that June of 1998.
Fourth, the school pre-approved the content of the course she was to teach to ensure that she
was really catechizing the students.
And fifth, the school had a program for subjecting Yamyamin to classroom evaluation.
Unfortunately, since she was new and it was just the start of the school year, Aquinas did not
have sufficient opportunity to observe her methods. At any rate, it acted promptly to relieve her
of her assignment as soon as the school learned of the incident. It cannot be said that Aquinas
was guilty of outright neglect.