One normal school day, a fourth grade student decided to use the boy’s comfort room on the third floor to answer the call of nature. Unfortunately, he got locked inside the bathroom due to a defective doorknob and could not get out. Panicking, the scared boy yelled several times for help and even banged and kicked the door, all to no avail.
Consequently, he decided to open the window to call for help but in the process of opening the window, he “went right through and fell down three stories.” The boy was rushed to the hospital where he was confined and given medical treatment for serious multiple physical injuries.
The Court found the school liable for torts under Article 2176 of the Civil Code for the injuries sustained by the child due to the school’s fault and negligence. Article 2176 provides that “whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done.” The school was liable for damages for its failure to fix a defective doorknob, despite having been notified of the problem, and failure to install safety grills on the window where the boy fell from.
The Court further ruled that under Article 2176, all that is needed to be proven in torts cases was sufficiently complied with. The law requires proof that: (1) there is damage suffered by the plaintiff; (2) the fault or negligence of the defendant or some other person for whose act he must respond; and (3) the connection of cause and effect between the fault or negligence and the damages incurred were complied.
The Court also found the doctrine of res ipsa loquitor applicable in the case to prove the fault or negligence of the school –
The doctrine of res ipsa loquitor applies where (1) the accident was of such character as to warrant an inference that it would not have happened except for the defendant’s negligence; (2) the accident must have been caused by an agency or instrumentality within the exclusive management or control of the person charged with the negligence complained of; and (3) the accident must not have been due to any voluntary action or contribution on the part of the person injured. Petitioners are clearly answerable for failure to see to it that the doors of their school toilets are at all times in working condition.
The fact that a student had to go through the window, instead of the door, shows that something was wrong with the door…
Our pronouncement that Timothy climbed out of the window because he could not get out using the door, negates petitioners’ other contention that the proximate cause of the accident was Timothy’s own negligence. The injuries he sustained from the fall were the product of a natural and continuous sequence, unbroken by any intervening cause, that originated from CLC’s own negligence (Child Learning Center, Inc. v. Tagorio, G.R. No. 150920, November 25, 2005, J. Azcuna).