Supreme Court Holds Private School Accountable in Bullying Case

The Supreme Court of the Philippines has held a school—Mother Goose Special School System, Inc., civilly liable for negligence after a bullying incident involving three grade school students.

In a press release dated April 28, the Supreme Court stated: “In a Decision written by Associate Justice Mario V. Lopez, the SC’s Second Division found that the school failed to address a punching incident involving three grade school students inside one of its classrooms.”

The Incident

*Names have been changed. Trigger Warning: This article involves harm to children.

The bullying incident, which the Decision cites as an antecedent, occurred in 2007 at the Mother Goose School in Dagupan City, Pangasinan.

It began when *Nathan lost his mechanical pencil, which another student, *Ryan found and took home. Days later, Nathan saw Ryan using the pencil and told him it was his, but allowed Ryan to keep using it for the time being. Ryan forgot to return it.

When Nathan again asked for the pencil, Ryan said he would return it later because he still didn’t have one of his own. Seated with them was *Matt. After the exchange, Matt punched Ryan’s left arm three times. Nathan followed with two punches, Matt added three more, and Nathan punched him three more times. Ryan was punched six times by Matt and five times by Nathan. Their teacher was in the comfort room during the incident.

Ryan reported the incident three days later to another teacher, saying, “Teacher, sinuntok nila ako.” The teacher took no action.

A few days later, a classmate noticed Ryan’s bruises and reported them to their class adviser. The class adviser questioned Ryan, called in Matt and Nathan, and both admitted to punching him. That same day, Nathan’s mother called Ryan’s mother to ask for an apology—the first time Ryan’s parents learned of the punching incident. Ryan’s father then took him to the municipal health office for a medical examination.

Ryan’s parents filed official complaints and requested an investigation from the school, but were ignored. When they finally received an investigation report, Ryan’s father noticed several inaccuracies in the findings, and disciplinary actions imposed on those involved, with the school downplaying the incident as “teasing” or “rough play.” Unsatisfied, Ryan’s parents then filed damages against Nathan and Matt’s parents, alleging that they are liable for the damages caused by Nathan and Matt; and the Mother Goose School, alleging that they were liable for negligence.

The Court’s Ruling

The Regional Trial Court (RTC) found the school and teacher-in-charge of the incident were liable, citing their duty to protect their students during school hours. The Court of Appeals (CA) upheld the ruling but cleared the teacher, who was absent during the incident.

The Supreme Court (SC) affirmed the CA’s ruling, emphasizing that schools have a contractual duty to provide a safe learning environment. The SC reiterated that schools must maintain peace and order not only within their premises but also during off-campus activities. Schools can avoid liability only by proving they exercised due diligence.

Moreover, the SC cited several grounds for finding the school grossly negligent:

• The school’s teachers were unequipped to address student complaints of physical harm.
• The school failed to inform Ryan’s parents immediately.
• The school did not have protocols in place for handling violence among students.
• The school conducted a formal investigation only upon the request of Ryan’s father.
• The school did not adequately provide updates to Ryan’s parents of the investigation.
• The school’s official investigation report was replete with inaccurate information, and no disciplinary action was taken against the offenders despite their own admission that they punched Ryan multiple times.

In the Decision, the SC emphasized: “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. Unfortunately, Mother Goose School failed in this regard.”

Mother Goose was ordered to pay the victim’s parents P650,000.00 in damages and attorney’s fees.

Sources (Originally published by the Supreme Court Public Information Office):

• Supreme Court Press Release
• Supreme Court Decision

Read here for 10 signs that your child is experiencing bullying in school.