Supreme Court penalizes school for negligence in bullying incident

MANILA, Philippines — The Supreme Court (SC) has ruled that a school in Pangasinan is civilly liable for negligence after a bullying incident on its premises led to the assault of a grade school student during class.

In a decision penned by Associate Justice Mario Lopez promulgated on January 25, the high court found that Mother Goose Special School System Inc. in Dagupan, Pangasinan, failed to adequately address a punching incident involving three of its grade school students that occurred inside a classroom.

As a consequence of its negligence, the high court ordered the school to pay the victim’s parents a total of P650,000 in damages and attorney’s fees. 

The case

The incident occurred in 2007 during a computer class, when two students repeatedly punched a classmate while the teacher was momentarily away in the comfort room.

Although the victim promptly reported the assault to his teachers, the Supreme Court noted that the school administration failed to take any meaningful action.

The victim's parents subsequently raised the issue with the school, but their complaints were reportedly ignored, prompting them to formally request an investigation. 

However, the school dismissed the incident as mere "teasing" or "rough play" and did not impose any disciplinary measures on the students involved.

Dissatisfied with the school's inaction, the parents filed a complaint for damages against the school, the teacher-in-charge, including the fathers of other students involved.

The Regional Trial Court (RTC) initially ruled that both the school and the teacher-in-charge were liable, emphasizing their duty to ensure the safety of students during school hours. 

The Court of Appeals (CA) upheld this decision but cleared the teacher who was not present when the bullying occurred.

Supreme Court ruling

The Supreme Court ultimately affirmed the appellate court’s ruling, saying that schools have a contractual obligation to provide and maintain a safe and secure learning environment for their students. 

The high court reiterated the responsibility of schools to maintain peace and order within their premises and even outside the campus during school-related activities. 

“Notably, every parent who entrusts their child to a learning institution does so with the assurance that the school, owing to its obligation not only to provide but also to maintain a safe learning environment, will protect the child from harm or will promptly address similar incidents after its occurrence,” the Supreme Court said. 

“Unfortunately, Mother Goose School failed in this regard,” it added. 

It also pointed out that schools can only avoid liability if they can prove they exercised due diligence in preventing the harm.

However, in the case of Mother Goose School, the high court found the institution negligent due to its lack of proper protocols for handling such incidents, its failure to promptly inform the victim’s parents about the assault and inaccuracies in its subsequent investigation.

The Supreme Court also acknowledged that while the incident constituted bullying in its general sense, the Anti-Bullying Act of 2013, which provides a specific legal definition and mandates schools to implement anti-bullying policies, was not yet in effect at the time of the incident.