Photo: Supreme Court/File
Photo: Supreme Court/File

MANILA — The Supreme Court of the Philippines has ruled that a school cannot be held liable for noise generated from its regular activities, saying these do not constitute a nuisance.

In a 17-page decision, the High Court’s Third Division granted the petition filed by the Couples for Christ School of the Morning Star (CFC-SMS) and overturned a ruling that awarded damages to subdivision residents in Butuan City.

“[T]he noise emanating from CFC-SMS constitutes academic noise, or sounds incident to the operation of an educational institution,” it said.

“Equally important, the sounds complained of from CFC-SMS do not exceed what might be reasonably expected from its school operations. Neither did CFC-SMS intentionally or unncessarily cause harm,” it later added.

Residents had complained of loud sounds from the school, including drums and bugles, teachers using microphones and megaphones, and students cheering during games at a multipurpose center.

CFC-SMS, for its part, said it has been operating since 2012 with the necessary permits and clearances.

A trial court initially dismissed the complaint, finding that residents failed to prove harm caused by the noise. However, the Court of Appeals later reversed the decision, prompting the school to elevate the case to the Supreme Court.

The High Court ruled that so-called “academic noise” does not qualify as a nuisance under the law.

It explained that while nuisance refers to disturbances that interfere with a person’s comfort, property, or enjoyment, courts must consider several factors in determining whether noise is actionable.

These include the reliability of noise tests, measures taken to reduce sound, compliance with allowable noise limits, intent to cause harm, the number of complainants, and the actions taken to address concerns.

The Court noted that CFC-SMS implemented steps to mitigate noise from its operations and that the complainants failed to show the sounds were unreasonably disturbing.

It also said there was no proof that the noise worsened a senior citizen’s medical condition, and noted that no other residents testified despite claims that neighbors were also affected.

“Living in a densely populated country such as the Philippines, where houses and businesses are suited in close proximity, amplifies people’s sensitivity to noise,” it said.

“However, not all kinds or levels of noise are actionable. Particulary, the Civil Code regards noise as nuisance only when it reaches an intensity that injures or endangers the health or safety of others, or annoys or offends the senses,” it added.

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