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NATIONAL IRRIGATION ADMINISTRATION v. IAC

FACTS:

The case involves a petition for review on certiorari filed by the National Irrigation Administration (NIA) seeking to annul the decision of the Intermediate Appellate Court affirming the decision of the Court of First Instance of Nueva Ecija. The private respondents, leasehold tenants of riceland, filed a complaint against the NIA for damages claiming that the two outlets constructed on the irrigation canal passing through their landholdings were not provided with gates, causing inundation and damage to their crops. After trial, the court issued a decision ordering the NIA to pay damages, attorney's fees, and costs. The NIA appealed the decision but the appellate court affirmed it. The NIA argued that it is immune from suit for quasi-delict or tort, and if it could be sued, it is not liable for tort as it did not act through a special agent. However, the court ruled that the NIA is not immune from suit under P.D. No. 552 and that it is liable for damages caused by its negligence. The court further found that the NIA's failure to provide necessary safeguards to prevent the inundation of the landholdings was the proximate cause of the damages. The court also upheld the award of damages, considering the evidence presented and the circumstances of the case. The petition for review on certiorari was denied by the court for lack of merit.

ISSUES:

  1. Whether the National Irrigation Administration (NIA) is immune from suit for quasi-delict or tort.

  2. Whether NIA is liable for tort since it did not act through a special agent.

RULING:

  1. The NIA is not immune from suit for quasi-delict or tort. This is supported by the provision of P.D. No. 552 which granted NIA the power to exercise all the powers of a corporation under the Corporation Law, except when inconsistent with the provisions of said law. Furthermore, the NIA can sue and be sued in court for all kinds of actions, whether contractual or quasi-contractual. The NIA is a government agency with a separate juridical personality, not a mere agency of the government.

  2. NIA is liable for damages caused by their negligent act. The court found that the NIA's failure to provide the necessary safeguards to prevent the inundation of the landholdings of the private respondents is the proximate cause of the damages. The NIA constructed irrigation canals on the landholdings without safety devices, resulting in the reduction of the annual harvest of the farmers. The existence of a check gate before the construction of the NIA irrigation canal does not absolve the NIA from liability.

PRINCIPLES:

  • The NIA is not immune from suit for quasi-delict or tort by virtue of the express provision of P.D. No. 552.

  • The NIA has its own corporate powers and is a separate juridical entity from the government.

  • Article 2176 of the Civil Code provides that whoever causes damage to another through fault or negligence is obliged to pay for the damage done. Such fault or negligence, if there is no pre-existing contractual relation between the parties, is called a quasi-delict and is governed by the provisions of the Civil Code.

  • The State is responsible for damages caused by a special agent, but not when the damage has been caused by the official to whom the task done properly pertains.