'Life is precious; no amount of damages can ever hope to replace it' -- SC
At A Glance
- "A wife who loses a husband is called a widow.
- A husband who loses a wife is called a widower.
- A child who loses his parents is called an orphan.
- There is no word for a parent who loses a child.
- That's how awful the loss is." – Jill Wieber Lens
“This Court does not mean to put a price on a person's life. The value of a human being is immeasurable. It is priceless. Yet the law, in all of its justice, deems it necessary that every injury -- more so the loss of life --be compensated in the form of damages.”
This was stressed by the Supreme Court (SC) as it reiterated its 2016 ruling: “Life is precious. No amount of damages can ever hope to replace it. Regrettably, this is the utmost extent to which the Court can intervene.”
In a full court decision written by Senior Associate Justice Marvic M.V.F. Leonen, the SC denied the appeal filed by the University of Southeastern Philippines and its officials and faculty members on the adverse ruling of the Court of Appeals which imposed damages for the death of student Chery Sarate on July 23, 2006.
Case records show that on July 20, 2006, the university’s Guild of English Students organized a beauty pageant in the school’s social hall.
For the pageant, the organizers installed a T-shaped ramp lined with 12 small, lit candles in brown paper bags filled with damp soil. Each paper bag was tied with crepe paper, and the opening of the bags were structured like crowns to resemble a lantern. Some of the social hall's lights were switched off to highlight the candlelight.
Cheryl was the fourth candidate to walk for the pageant. She wore a snow fairy ensemble made of cotton balls glued to plastic cellophane typically used to cover books. The lower skirt was on a tie-wire to create a petticoat design. Its hem was covered with small feathers. Her tube blouse was covered with rolled cotton flattened to her chest. The top of her blouse was attached to a tie-wire. She held a rattan scepter and wore a butterfly headdress.
While Cheryl was standing on the leftmost side of the T-shaped ramp, her gown caught fire as she turned to pose. When she turned right to walk to the center ramp, she used her bare hands to ward off the small flames that started to engulf her.
However, when she was at the center ramp, the flames blazed, causing Cheryl to jump over the right side of the hall where the audience sat. She tripped as she screamed for help. Some students tried to help, and the fires were eventually put out. The ambulance arrived 30 minutes later and Cheryl was brought to the hospital.
On July 23, 2006, Cheryl died in the hospital due to "cardiac arrest due to septic shock, the antecedent cause is secondary to flame burn 80 percent total body surface area (TBSA) involving face, neck, anterior chest, back both upper and lower extremities."
Cheryl’s parents, Antonio and Rosita Sarate, filed a case for damages against the university, its officials, and pageant organizer.
On Oct. 7, 2014, the regional trial court (RTC) declared the university and those charges jointly and severally liable.
They were ordered to pay P50,000 for the death of Cheryl; P200,000 for exemplary or corrective damages; P500,000 for moral damages, and attorney’s fees equivalent to 20 percent of the total amount.
In its ruling, the RTC invoked Article 2180 of the Civil Code in relation to Articles 218 and 219 of the Family Code. It said that “the obligation under Article 217621 of the Civil Code is demandable for those of persons for whom one is responsible, and that employers are liable for damages caused by employees acting within the scope of their assigned tasks.”
On a motion filed by the university, the RTC – in an order issued on Dec. 22, 2014 – absolved the university from liability and declared the pageant organizer and faculty members as liable.
The spouses Sarate elevated the case to the Court of Appeals (CA) which granted the appeal and reinstated the RTC’s Oct. 7, 2014 decision.
The CA found the university liable through its administrators and officers-in-charge “since there was collective negligence” between them and the pageant organizer.
The university and its officials elevated the case to the SC.
The SC said that the petitioners -- being the school, its administrators, and its teachers -- have special parental authority and responsibility over the members of the Guild that conducted the pageant.
“They are principally and solidarily liable for damages caused by them, and this liability applies to all their authorized activities,” it said.
It also said that “petitioners attempt to escape liability by arguing that the beauty pageant organized by the Guild was an unauthorized activity. They insist that: (1) the Guild did not have the required permit to hold the event, making it a private affair; and (2) the pageant, which was held on a weekday, violated the school policy to hold extracurricular activities only during weekends.”
“However, as pointed out by the Court of Appeals, the activity pushed through on campus grounds, inside the social hall, despite the alleged lack of permit and approval,” it added.
At the same time, the SC stressed: “These petitioners are not ordinary tortfeasors. They are teachers, officers, and directors of a school which, by law, has special parental authority and responsibility over minors under its supervision, instruction, or custody. At the very least, petitioners should have conducted their school activities in a safe and careful manner because respondents, as parents, expected them to keep Cheryl, their minor child, well and safe. Petitioners miserably failed to do both.”
The dispositive portion of the SC decision: “Accordingly, the Petition for Review on Certiorari is denied. The Court of Appeals' Aug. 31, 2018 Decision and May 23, 2019 Resolution in CA-G.R. CV NO. 04623-MIN are affirmed with modification in that petitioners are hereby ordered to pay respondents Antonio and Rosita Sarate, jointly and severally, the following amounts as damages:(1) Civil indemnity of P300,000 for the death of Cheryl Sarate; (2) moral damages of P5,000,000; exemplary damages of P1,000,000; and ( 4) attorney's fees of P150,000. The total monetary amount due shall earn legal interest of six percent per annum, reckoned from the time of finality of this Decision until its full satisfaction.”