12/06/2026
Many have inquired whether Ateneo de Manila University may be held liable for the untimely death of two varsity basketball players. A number of legal opinions suggest that liability may arise if the school’s personnel—such as coaches, trainers, or teachers—who supervised and conducted the training are shown to have been negligent. In such a case, the University, as employer, may be held liable under the principle of vicarious liability pursuant to Article 2180 of the Civil Code.
The crucial issue, however, is the determination of negligence. Article 1173 of the Civil Code defines negligence as the omission of the diligence required by the nature of the obligation and corresponding to the circumstances of the persons, time, and place. Thus, the standard is not fixed but varies depending on the situation.
In the context of educational institutions, Article 218 of the Family Code provides that schools exercise special parental authority and responsibility over their students. This entails a duty to act with the care and prudence of a good father of a family (bonus pater familias), ensuring the safety and well-being of students under their supervision.
It may be argued that such parental authority applies only to minor students. However, jurisprudence has clarified otherwise. In Palisoc v. Brillantes, the Supreme Court categorically held that a school’s authority and custodial supervision over its students exist regardless of age. While the degree of responsibility may be less stringent for students of majority age, the duty itself subsists.
Accordingly, by enrolling and participating in school-sanctioned activities, even adult students place themselves under the supervision and control of school authorities. This includes athletic programs conducted under the school’s auspices.
Therefore, the determination of liability hinges on whether Ateneo, through its coaches and trainers, exercised the diligence required under the circumstances. This includes ensuring that training methods are safe, appropriate to the physical condition of the players, and conducted with due regard to their health and welfare.
A practical and persuasive test may be posed: if the players were their own sons, would the coaches and trainers have allowed them to undergo the same training under the same conditions? If the answer is in the negative, this may strongly indicate a failure to exercise the required diligence.
In sum, if it is established that the school’s representatives failed to observe the degree of care expected under the circumstances, and that such failure was the proximate cause of the deaths, then Ateneo de Manila University may be held civilly liable under the Civil Code.
