Joseph Azil Buena

The Supreme Court (SC), in a full decision on January 20 and released on April 28, ordered Mother Goose Special School System, Inc. in Pangasinan to recompense PHP 650,000 in civil liabilities over their negligence in handling a bullying incident inside their school.

Photo Courtesy of Mother Goose Special School System, Inc.

In its 16-page decision, the SC Second Division affirmed that Mother Goose School failed to properly address a punching incident involving three grade school students inside a classroom in 2007.

According to accounts in the decision, the incident occurred during class when an argument over a missing pencil resulted in two students repeatedly punching a classmate while the subject teacher was in the restroom.

Several days passed before the victim had reported the incident to his teachers, but ‘no meaningful action’ was taken by any of them.

However, two students admitted to punching their classmate, as told to their class adviser.

The victim's parents eventually raised the issue with Mother Goose School, but were ignored, compelling them to file formal requests for an investigation by the school.

Ultimately, the school took no disciplinary action and concluded that the incident was mere “teasing” or “rough play” among the students in class, leading the parents to file a legal complaint.

In an initial decision from 2017, the Regional Trial Court held Mother Goose School and the subject teacher who was in the bathroom jointly liable for failing to protect the student during class hours, citing their parental duty and inattention towards the bullying.

The respondents appealed the case to the Court of Appeals (CA) soon after.

Still, in 2023, the CA affirmed the RTC ruling but cleared the teacher due to his absence during the incident, also classifying the act as bullying under the Anti-Bullying Act of 2013, and holding the school solely accountable.

The recent ruling of the SC affirmed this decision with finality, stressing that educational institutions are “contractually bound to provide a safe and secure learning environment” for students.

It highlighted that schools are responsible for maintaining order both on campus and during off-site activities, and can only escape liability if they clearly demonstrate due diligence.

Taking from the CA decision, the SC ruled the school was negligent specifically upon its lack of proper protocols, failure to inform the victim’s parents, and inaccuracies in its investigation.

“Clearly, there is preponderant evidence to support a finding of gross negligence on the part of Mother Goose School. By failing to address the harm committed by one student against another and by negligently handling the punching incident after it had already happened, Mother Goose School failed to exercise the diligence in providing a safe learning environment to its students,” the SC said.

The SC added that the term ‘bullying’ was to be considered in its generic meaning, and not as defined by the Anti-Bullying Act of 2013, which was not yet enacted at the time.

The said law, which took effect in September 2013, mainly mandates all schools in the Philippines to set and implement policies for preventing and responding to bullying among students to provide a "safe and supportive learning environment."