By Benjamin Cuaresma
MANILA — The Supreme Court has ruled that noise from regular school operations inside a residential subdivision cannot be a basis for damages, saying academic activities during class hours fall within “normal tolerability” under the law.
In a decision released Wednesday, April 16, the SC denied a damage suit filed by homeowners against a private school operating inside their subdivision.
The Court held that bells, assemblies, announcements, and student activities during school hours are ordinary incidents of education and foreseeable in areas where schools are allowed.
“Article 844 of the Civil Code does not prohibit all emissions, only those that exceed normal tolerability considering the condition of the place,” the Court said.
“A school with proper permits, operating within reasonable hours, cannot be held liable for noise that is customary to its function.”
The SC reiterated that there is no absolute decibel cutoff for noise. Trial courts must weigh time of day, intensity, frequency, and the character of the locality. Daytime academic noise in a subdivision where a school is validly zoned is generally tolerable. Late-night amplified events or activities done in bad faith could still be actionable if proven harmful.
The school presented zoning clearance, business permits, and proof it adjusted bell schedules and speaker volumes after complaints.
Finding no malice, negligence, or abnormal noise levels, the Court said moral and exemplary damages could not be awarded.
“Without bad faith or injury beyond ordinary discomfort, there is no cause of action for damages,” the ruling read.
The SC clarified that residents are not without remedy. They may seek LGU mediation, ask the school to adopt noise mitigation, or pursue zoning enforcement if the school violates conditions.
ia/xf
