Short answer. Yes, potentially. Teachers or heads of establishments of arts and trades are liable for damages caused by their pupils, students, or apprentices while those students remain in their custody, unless the teacher proves having observed all the diligence of a good father of a family to prevent the harm.
What the law says
Lastly, teachers or heads of establishments of arts and trades shall be liable for damages caused by their pupils and students or apprentices, so long as they remain in their custody.
Civil Code, Article 2180 — Vicarious Liability. Read the full provision →
This provision fits a vocational training setting directly
The statute singles out teachers or heads of establishments of arts and trades as liable for damages caused by their pupils, students, or apprentices. A vocational training class is exactly the kind of arts-and-trades setting this clause addresses, distinguishing it from the separate rule elsewhere in the same article for teachers in an ordinary academic school setting. The injuring student being under instruction at the time is central to whether this specific clause applies.
The custody requirement
Liability under this clause runs only so long as the student remains in the teacher's or establishment head's custody. If the injury happened during the lesson itself, while the instructor had supervisory control over the class, that custody element is generally present. This is a vicarious liability — the law imposes it on the teacher or establishment head for someone else's act, not because the teacher personally caused the injury.
The diligence defense can defeat the claim
This liability is not absolute. The article expressly allows the responsibility to cease where the teacher or head of the establishment proves having observed all the diligence of a good father of a family to prevent the damage. This means a teacher who took reasonable precautions appropriate to the activity — proper supervision, safety instruction, and reasonable safeguards for the tools or equipment involved in a vocational lesson — has a real defense, even if an injury still occurred.
The underlying basis: fault or negligence
This vicarious liability rests on the same foundation as ordinary civil liability for negligence: it is demandable because of fault or negligence causing damage where there is no pre-existing contract between the injured party and whoever is responsible. That means the analysis still depends on how the injury happened and what precautions were or were not taken — this provision extends who can be held liable for that negligence, it does not remove the need to show negligence played a role in the injury.
Cases citing this provision
These Supreme Court decisions cite the provision above. We list them so you can read them yourself; the summaries of what each decided are not ours to give.
- Pedro De Belen and Bejan Mora Semilla vs. Virginia Gebe Fuchs, G.R. No. 258557, October 23, 2023 — read the decision on LawPhil →
- Caravan Travel and Tours International, Inc. vs. Ermilinda R. Abejar, G.R. No. 170631, February 10, 2016 — read the decision on LawPhil →
- Greenstar Express, Inc. and Fruto L. Sayson, Jr. vs. Universal Robina Corporation and Nissin Universal Robina Corporation, G.R. No. 205090, October 17, 2016 — read the decision on LawPhil →
- CICL XXX vs. People of the Philippines, G.R. No. 238798, March 14, 2023 — read the decision on LawPhil →
Related provisions
- Civil Code, Article 2180 — Vicarious Liability
- Civil Code, Article 2176 — Quasi-Delict Defined (Culpa Aquiliana)