View full case

NATIVIDAD V. ANDAMO v. IAC

FACTS:

The petitioners, spouses Emmanuel and Natividad Andamo, own a parcel of land in Cavite which is adjacent to the land of the private respondent, Missionaries of Our Lady of La Salette, Inc. On the respondent corporation's land, there were constructions such as waterpaths, water conductors, and an artificial lake. These constructions allegedly caused inundation, erosion, and damage to the petitioners' land. Furthermore, these constructions resulted in a young man drowning, destruction of crops and plants, damage to fences, and the endangered lives of the petitioners and their laborers during the rainy and stormy seasons. In July 1982, the petitioners initiated a criminal action against the officers and directors of the respondent corporation, charging them with destruction through inundation. They also filed a civil case seeking damages and a writ of preliminary injunction. However, the trial court dismissed the civil case for lack of jurisdiction because there was a pending criminal case. The dismissal was upheld by the Appellate Court. The petitioners argue that the dismissal was erroneous, asserting that their civil case is based on a quasi-delict. They contend that the nature of the action should be determined by the allegations in the complaint, and since their complaint clearly indicates a quasi-delict, the dismissal should not have been justified.

ISSUES:

  1. Whether a corporation can be held civilly liable for damages under Articles 2176 and 2177 of the Civil Code for causing inundation and damage to adjacent land.

  2. Whether the civil case can proceed independently of the criminal case.

RULING:

  1. Yes, a corporation can be held civilly liable for damages under Articles 2176 and 2177 of the Civil Code for causing inundation and damage to adjacent land.

  2. Yes, the civil case can proceed independently of the criminal case.

PRINCIPLES:

  • The nature of an action filed in court is determined by the facts alleged in the complaint as constituting the cause of action.

  • Pleadings and remedial laws should be liberally construed to avoid denial of substantial justice.

  • A corporation can be held civilly liable for quasi-delicts committed by its agents.

  • Criminal and civil actions arising from the same offense may be instituted separately, but the civil action can be instituted even if the criminal action has already commenced.