17/04/2026
SUPREME COURT: NOISE FROM REGULAR SCHOOL ACTIVITIES NOT CONSIDERED NUISANCE IN RESIDENTIAL AREAS
The Supreme Court (SC) ruled that schools cannot be held liable for damages for noise or sounds coming from its regular activities such as drums, bugles and teachers speaking through megaphones, as these are not considered a nuisance in residential areas.
In a 17-page decision authored by Associate Justice Samuel Gaerlan, the SC's Third Division granted the petition filed by the Couples for Christ School of the Morning Star (CFC-SMS) and reversed a ruling that awarded damages to residents Saint Joseph Subdivision in Barangay Villa Kananga, Butuan City, where the school is situated.
The case stemmed from a civil complaint filed by a group of residents of the subdivision led by Wideline Malonda, who claimed that they were often exposed to loud noises from the school, such as drums and bugles being played, teachers speaking through microphones and megaphones, and students running, cheering, and shouting during games played at the multipurpose center.
The residents sought damages, as according to their contentions these sounds, heard day and night, disturbed their sleep and peace at home. Meanwhile, in its defense, the school said it has been operating since 2012 with the necessary permits and clearances and that any noise comes only from regular classes.
It added that the City Environment and Natural Resources Office conducted a test and found the noise to be within the allowed limits for residential areas. The school also claimed it took steps to reduce noise, such as building higher fences, planting trees, using small speakers, and limiting activities to 7:00 a.m. to 7:00 p.m. on weekdays.
The Regional Trial Court (RTC) initially dismissed the residents’ complaint, ruling that they failed to prove they were harmed by the noise. It also noted that the school did not intend to harm the residents and acted in good faith by taking steps to reduce the noise.
When elevated before the Court of Appeals (CA), the appellate court ruled in favor of the residents case, holding that the school's noise, which came not only from classes but also from other social functions in the multi-purpose hall, was a nuisance that caused discomfort and annoyance to the residents. This prompted the school to seek an appeal before the Supreme Court.
In abandoning the CA decision, the high court held that academic noise, or sounds from legitimate school activities, is not a nuisance. It found that the residents failed to establish that the school willfully made such noise with malice.
“Absent a preponderance of evidence rendering CFC-SMS liable, the action for damages against it is dismissed,” the SC said.
The SC said the CA “erroneously” relied on the tests conducted by the Department of Environment and Natural Resources in 2017 that the ambient noise exceeded 55 decibels, which was beyond the threshold for residential areas under the rules of the National Pollution Control Commission.
“There is no law that states that a violation of the noise level limits would result in an automatic finding of nuisance,” the SC said.
It reiterated its ruling in Frabelle Properties Corp. v. AC Enterprises, Inc., which held that in resolving cases involving complaints of noise as a nuisance, the court must consider the following factors: (1) the reliability of the noise pollution tests conducted; (2) the defendant’s introduction of measures or improvements to mitigate the noise; (3) applicable allowable noise levels; (4) the defendant’s intent, or lack thereof, to cause harm to the plaintiff; (5) the number of complaining witnesses; (6) the representativeness of the plaintiffs; and (7) the actions taken by the plaintiff to alleviate his or her condition.
The highest bench underscored that the sounds coming from the school originated from its ordinary operations as an educational institution and that the respondents are hardly representative of the community.
It also emphasized that the residents failed to prove that the noise was unreasonably disturbing and that it worsened their health conditions, as their statements showed only minor discomforts, not serious harm.
The SC added that while location and environment are important in determining a nuisance, they must be weighed against whether the noise is normally expected from the activity involved. Here, the sounds complained of did not go beyond what could be reasonably expected from a school.
It noted that there is no nuisance if an ordinary person would not find the sound disturbing, even if someone else is unusually sensitive to it.
