Pedro is a long-time resident of a subdivision. Inside the subdivision is a school. Pedro’s house is near said school. He narrates that the neighborhood frequently gets bombarded by noise from the school. Students would play drums and other instruments. Teachers would yell out instructions through megaphones. Audiences and players would cheer, roar, and clap during sports events. Unable to bear the noise anymore, Pedro filed a case to declare the noise as a nuisance, for the court to order abatement of the nuisance, and for damages.

What is a nuisance?

Under Article 694 of the Civil Code, a nuisance is defined as “any act, omission, establishment, business, condition of property, or anything else which: (1) Injures or endangers the healthor safety of others; or (2) Annoys or offends the senses; or(3) Shocks, defies or disregards decency or morality; or (4) Obstructs or interferes with the free passage of any public highway or street, or any body of water;or (5) Hinders or impairs the use of property.” Based on case law, however, the term “nuisance” is deemed to be “so comprehensive that it has been applied to almost all ways which have interfered with the rights of the citizens, either in person, property, the enjoyment of his property, or his comfort.”

So is the school noise a nuisance that can be halted by the courts? The Court said no, it cannot stop the noise from a school.

Living in a densely populated country such as the Philippines, where houses and businesses are situated in close proximity, amplifies people’s sensitivity to noise. However, not all kinds or levels of noise are actionable. Particularly, the Civil Code regards noise as a nuisance only when it reaches an intensity that injures or endangers the health or safety of others, or annoys or offends the senses.

In addressing the issue, this Court considered a myriad of factors beyond simply the locality and
character of the sun-oundings and the impact on the health and comfort of the residents. Particularly, this Court likewise considered the (i) reliability of the noise pollution tests conducted, (ii) introduction by the defendant of measures or improvements to mitigate the noise, (iii) allowable noise levels, (iv) defendant’s intention ( or lack thereof) to cause the plaintiff harm, ( v) number of complaining witnesses, (vi) representativeness of the plaintiff, and (vii) actions of the plaintiff to alleviate his or her plight.

Taken together, the Court noted that the noise emanating from the school constitutes academic noise, or sounds incident to the operation of an educational institution.

Couples for Christ School of the Morning Star v. Malonda et al., G.R. No. 278875. November 26, 2025.