Beyond the blackboard: A school's 'built-in' duty to provide a conducive atmosphere for learning

Schools are not just centers of academic instruction. Years spent in school play a vital role in shaping a child's character. As noted by the Supreme Court (SC) in the recently decided case of Mother Goose Special School System, Inc. v. Spouses Palaganas, G.R. No. 267331 (2025 Mother Goose Case), 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 to support his learning.

- AMICUS CURIAE CHRISHA VER R. ROMANO-WEIGEL

In the 2025 Mother Goose Case, the school was held monetarily liable for damages in the amount of P650,000 over a bullying incident on its premises. Rhys, a student at Mother Goose, was physically assaulted by classmates Noel and Mark. Reports to school officials led to no action and, despite their admission, Noel and Mark faced no consequences. Calls for investigation also resulted in inaccuracies in the school’s report, with the school downplaying the incident as a “form of teasing” and describing it as “natural and part of the growing up process.”

The SC, in finding the school liable, explained that Mother Goose’s liability arose from breaching its contractual obligation to provide and maintain a safe learning environment for its students (culpa contractual). Citing the landmark case of Philippine School of Business Administration v. CA, G.R. No. 84698, the SC explained that when an academic institution accepts students for enrollment, there is established a contract between them, resulting in bilateral obligations — for its part, the school undertakes to provide education to equip the student with the necessary skills to pursue higher education or a profession; on the other hand, the student commits to abide by the school’s academic requirements and rules and regulations.