(Amadora v.

Ca)
GR. No. l-47745 Apr. 15, 1988

Facts: On April 13, 1972, Alfredo Amadora, was at the Auditorium of Colegio de San
Jose-Recoletos to present his Chemistry report, a prerequisite for him to be able to
graduate 3 days later, but during the said day a classmate of his named Pablito
Daffon shot him which caused his death.

Issue: 1.)Whether or not Article 2180 of the Civil Code applies to all types of schools
and not merely limited to non-academic(Vocational or technical) institutions.

2.) Whether or not the responsibility of the teachers co terminus with the
period under which the student is undergoing studies during the school term.

Held: Yes, The Court held that there is no distinctions between a non academic and
an academic institutions, that the same vigilance is required of teachers over the
students under his control and supervision, whatever the nature of the school he is
teaching in. For notably, the injury subject of the liability is caused by the student
and not by the school itself nor is it a result of the operations of the school or its
equipment. The injury may be caused by any student, regardless of the school where
he is registered.
As to the period, the court held that the responsibility of the teachers extend
to periods between semesters wherein they are registering or enrolling and in the
case of the deceased, even after the suspension of classes and before his
commencement exercises, the court argues that it is too tenous to argue that the
student comes under the discipline of the school only upon the start of the classes
notwithstanding the fact that before that day, he had already registered and is thus
placed under their rules. Neither should such discipline be deemed ended upon the
last day of classes notwithstanding that there are still requisites to be satisfied for
the completion of the course. During such periods, the student is still subject to the
disciplinary authority of the school and cannot consider himself released from the
observance of its rules. As long as it can be shown that the student is in school
premises in pursuance of a legitimate student right, or enjoyment of a student right
or privilege, the responsibility of the school over the student continues.

*historically the heads of non academic institutions exercised closer tutelage of their
students than the head of academic schools. The old schools of arts and trades were
engaged in the training of artisans apprenticed to their masters who personally and
directly instructed on the secrets and technique of their craft. Where the Head of the
School of are the Masters who are personally involved in the task of teaching his
students who usually boarded with him and so came under his constant control,
supervision and influence.