22/04/2026
The (SC) has ruled that sounds incident to the operation of an educational institution, those arising from a schoolโs regular activities, are not considered a nuisance and cannot make the school liable for damages.
In a Decision written by Associate Justice Samuel H. Gaerlan, the SCโs Third Division granted the petition of Couples for Christ School of the Morning Star (School) and reversed the Court of Appealsโ (CA) ruling that awarded damages to residents of Saint Joseph Subdivision in Barangay Villa Kananga, Butuan City, where the school is located.
Wideline I. Malonda and others, who are residents of the Subdivision, claimed 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 claimed that these sounds, heard day and night, disturbed their sleep and peace at home.
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) dismissed the residentsโ complaint, ruling that they failed to prove they were harmed by the noise. The RTC also found that the School did not intend to harm the residents and acted in good faith by taking steps to reduce the noise.
On appeal, the CA ruled in the residentsโ favor, holding that the Schoolโs 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.
The SC overturned the CAโs ruling. It held that academic noise, or sounds from legitimate school activities, is not a nuisance.
Nuisance includes any disturbance that interferes with a person, property or comfort and enjoyment of all citizens. The SC ruled that the determination of whether a noise is a nuisance requires more than just considering the location, environment, and its effect on residents.
Thus, for noise to be considered nuisance, the SC considered in the ๐๐ณ๐ข๐ฃ๐ฆ๐ญ๐ญ๐ฆ ๐๐ณ๐ฐ๐ฑ๐ฆ๐ณ๐ต๐ช๐ฆ๐ด ๐๐ฐ๐ณ๐ฑ. ๐ท. ๐๐ ๐๐ฏ๐ต๐ฆ๐ณ๐ฑ๐ณ๐ช๐ด๐ฆ๐ด ๐๐ฏ๐ค. the:
1. reliability of the noise pollution tests conducted,
2. introduction by the defendant of measures or improvements to mitigate the noise,
3. allowable noise levels,
4. defendantโs intention (or lack thereof) to cause harm to the plaintiff,
5. number of complaining witnesses,
6. representativeness of the plaintiff, and
7. actions of the plaintiff to alleviate his or her plight.
Adopting the framework, the SC finds that the sounds emanating from the School arose from its ordinary operations as an educational institution, and that the respondents are hardly representative of the community.
The SC also ruled that the residents failed to prove that the noise was unreasonably disturbing and that it worsened their health conditions. The residentsโ 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.
The SC emphasized that there is no nuisance if an ordinary person would not find the sound disturbing, even if someone else is unusually sensitive to it.
The SC explained:
โ๐๐ช๐ท๐ช๐ฏ๐จ ๐ช๐ฏ ๐ข ๐ฅ๐ฆ๐ฏ๐ด๐ฆ๐ญ๐บ ๐ฑ๐ฐ๐ฑ๐ถ๐ญ๐ข๐ต๐ฆ๐ฅ ๐ค๐ฐ๐ถ๐ฏ๐ต๐ณ๐บ ๐ด๐ถ๐ค๐ฉ ๐ข๐ด ๐ต๐ฉ๐ฆ ๐๐ฉ๐ช๐ญ๐ช๐ฑ๐ฑ๐ช๐ฏ๐ฆ๐ด, ๐ธ๐ฉ๐ฆ๐ณ๐ฆ ๐ฉ๐ฐ๐ถ๐ด๐ฆ๐ด ๐ข๐ฏ๐ฅ ๐ฃ๐ถ๐ด๐ช๐ฏ๐ฆ๐ด๐ด๐ฆ๐ด ๐ข๐ณ๐ฆ ๐ด๐ช๐ต๐ถ๐ข๐ต๐ฆ๐ฅ ๐ช๐ฏ ๐ค๐ญ๐ฐ๐ด๐ฆ ๐ฑ๐ณ๐ฐ๐น๐ช๐ฎ๐ช๐ต๐บ, ๐ข๐ฎ๐ฑ๐ญ๐ช๐ง๐ช๐ฆ๐ด ๐ฑ๐ฆ๐ฐ๐ฑ๐ญ๐ฆโ๐ด ๐ด๐ฆ๐ฏ๐ด๐ช๐ต๐ช๐ท๐ช๐ต๐บ ๐ต๐ฐ ๐ฏ๐ฐ๐ช๐ด๐ฆ. ๐๐ฐ๐ธ๐ฆ๐ท๐ฆ๐ณ, ๐ฏ๐ฐ๐ต ๐ข๐ญ๐ญ ๐ฌ๐ช๐ฏ๐ฅ๐ด ๐ฐ๐ณ ๐ญ๐ฆ๐ท๐ฆ๐ญ๐ด ๐ฐ๐ง ๐ฏ๐ฐ๐ช๐ด๐ฆ ๐ข๐ณ๐ฆ ๐ข๐ค๐ต๐ช๐ฐ๐ฏ๐ข๐ฃ๐ญ๐ฆ. ๐๐ข๐ณ๐ต๐ช๐ค๐ถ๐ญ๐ข๐ณ๐ญ๐บ, ๐ต๐ฉ๐ฆ ๐๐ช๐ท๐ช๐ญ ๐๐ฐ๐ฅ๐ฆ ๐ณ๐ฆ๐จ๐ข๐ณ๐ฅ๐ด ๐ฏ๐ฐ๐ช๐ด๐ฆ ๐ข๐ด ๐ข ๐ฏ๐ถ๐ช๐ด๐ข๐ฏ๐ค๐ฆ ๐ฐ๐ฏ๐ญ๐บ ๐ธ๐ฉ๐ฆ๐ฏ ๐ช๐ต ๐ณ๐ฆ๐ข๐ค๐ฉ๐ฆ๐ด ๐ข๐ฏ ๐ช๐ฏ๐ต๐ฆ๐ฏ๐ด๐ช๐ต๐บ ๐ต๐ฉ๐ข๐ต ๐ช๐ฏ๐ซ๐ถ๐ณ๐ฆ๐ด ๐ฐ๐ณ ๐ฆ๐ฏ๐ฅ๐ข๐ฏ๐จ๐ฆ๐ณ๐ด ๐ต๐ฉ๐ฆ ๐ฉ๐ฆ๐ข๐ญ๐ต๐ฉ ๐ฐ๐ณ ๐ด๐ข๐ง๐ฆ๐ต๐บ ๐ฐ๐ง ๐ฐ๐ต๐ฉ๐ฆ๐ณ๐ด, ๐ฐ๐ณ ๐ข๐ฏ๐ฏ๐ฐ๐บ๐ด ๐ฐ๐ณ ๐ฐ๐ง๐ง๐ฆ๐ฏ๐ฅ๐ด ๐ต๐ฉ๐ฆ ๐ด๐ฆ๐ฏ๐ด๐ฆ๐ด.โ
The SC also denied the claim for damages since the School did not intend to harm or annoy the residents and had taken steps to reduce the noise. There was no evidence that the school caused the noise willfully, with malice or bad faith.
Read the full text of the press release at https://sc.judiciary.gov.ph/?p=163502
Read the full text of the Decision https://sc.judiciary.gov.ph/?p=163486
Read the Concurring Opinion of Associate Justice Alfredo Benjamin S. Caguioa at https://sc.judiciary.gov.ph/278875-formerly-udk-no-18061-concurring-opinion-justice-alfredo-benjamin-s-caguioa/
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