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NATIONAL POWER CORPORATION v. CA

FACTS:

The National Power Corporation (NPC), a government-owned and controlled corporation tasked with developing hydroelectric power and supplying electricity nationwide, built and operated the Agus Regulation Dam in 1978 as instructed by Memorandum Order No. 398 of the Office of the President. The purpose of the dam was to preserve the Lake Lanao watershed. Private respondents, who owned fishponds along the Lake Lanao shore, suffered damage when their fishponds were washed away due to a flood caused by an increase in the water level of the lake. They blamed the NPC for failing to increase the outflow of water despite the rising water level and sought compensation for the damages suffered. NPC denied the allegations and argued that the private respondents' fishponds were either located below the prohibited level or were introduced when the water level was abnormally low. The trial court ruled in favor of the private respondents, and the decision was affirmed by the Court of Appeals with modification on the damages awarded. NPC appealed the decision, arguing that the Court of Appeals disregarded Memorandum Order No. 398's mandate and erred in concluding negligence on its part. The Supreme Court found no reversible error committed by the Court of Appeals and affirmed its decision.

ISSUES:

  1. Whether or not the Court of Appeals erred in affirming the trial court's findings of fact and appreciation of evidence regarding petitioner's liability for the damages suffered by private respondents.

  2. Whether or not Memorandum Order No. 398 grants the National Power Corporation (NPC) the power and duty to maintain the normal maximum lake elevation at 702 meters and to build benchmarks to warn against cultivation below said elevation.

  3. Whether or not the NPC breached its duties to maintain the water level of the lake and release more water during the rainy season, resulting in flooding and damages to the neighboring properties.

  4. Whether the doctrine of res ipsa loquitur is applicable in this case

  5. Whether NPC is liable for damages caused by the flooding of the fishponds

  6. Whether the principle of damnum absque injuria applies in this case

  7. Whether the private respondents are entitled to compensation for damages

  8. What is the issue in this case?

  9. What is the ruling of the court regarding the issue raised?

RULING:

  1. The Court affirms the ruling of the Court of Appeals, stating that only questions of law can be raised in a petition for review. The Supreme Court does not weigh anew the evidence already passed upon by the Court of Appeals, unless the findings are not supported by substantial evidence. In this case, the Court finds no reversible error in the factual findings of the Court of Appeals.

  2. Memorandum Order No. 398 grants the NPC the power to build the Agus Regulation Dam and operate it for the purpose of generating energy. It also imposes the duty on the NPC to maintain the normal maximum lake elevation at 702 meters and build benchmarks to warn against cultivation below said elevation. The language of the presidential order is clear in conferring such power and duty to the NPC.

  3. The NPC breached its duties to maintain the water level of the lake at 702 meters and release more water during the rainy season. Evidence shows that before the construction of the Agus Regulation Dam, no reports of damages to landowners around the lake were heard. However, after its construction, reports and complaints of damages due to overflooding became widespread. The NPC's construction of the Intake Regulation Dam, which controls and regulates the amount of water discharged into the Agus River, resulted in the inundation of lands around the lake during high water levels. The NPC's holding back of water to maintain the volume required for power generation caused the flooding and damages in the neighboring properties.

  4. The doctrine of res ipsa loquitur is applicable in this case. It affords reasonable evidence, in the absence of an explanation by the defendant, that the accident arose from want of care.

  5. NPC is liable for damages caused by the flooding of the fishponds. It is the duty of NPC to maintain the water level of the dam within the benchmarks and to warn the inhabitants in the area that cultivation below the 702-meter elevation is forbidden. NPC failed to maintain the benchmarks and did not demonstrate that the fishponds were situated below the 702-meter level.

  6. The principle of damnum absque injuria does not apply in this case. NPC's negligence in failing to maintain the water level in its dams has been extensively established.

  7. The private respondents are entitled to compensation for damages. However, they failed to present independent evidence to prove the actual amount of loss. The Court of Appeals awarded temperate or moderate damages in reduced amounts, which are reasonable under the circumstances.

  8. The issue in this case is not mentioned in the text provided.

  9. The ruling of the court is that the Decision dated 21 December 1995 and the Resolution dated 27 March 1996 of the Court of Appeals in CA-G.R. CV No. 44639 are affirmed. The costs of the case are to be borne by the petitioner.

PRINCIPLES:

  • The Supreme Court is not a trier of facts and generally does not weigh anew the evidence already passed upon by the Court of Appeals.

  • Factual findings of the Court of Appeals that are supported by substantial evidence bind the Supreme Court.

  • Memorandum Order No. 398 grants the NPC the power and duty to maintain the normal maximum lake elevation at 702 meters and build benchmarks to warn against cultivation below said elevation.

  • In cases where flooding and damages occur due to the holding back of water by the NPC, it can be inferred that the incident happened because of NPC's failure to maintain the water level of the dam within the benchmarks at the maximum normal lake elevation.

  • Res ipsa loquitur - the thing speaks for itself; where the thing which causes injury is shown to be under the management of the defendant, and the accident is such as in the ordinary course of things does not happen if those who have the management use proper care, it affords reasonable evidence, in the absence of an explanation by the defendant, that the accident arose from want of care.

  • Duty of NPC under Memorandum Order No. 398 - to maintain the water level of the dam within the benchmarks and to build and maintain benchmarks to warn inhabitants in the area that cultivation below the 702-meter elevation is forbidden.

  • Negligence - failure to use proper care resulting in damage to another; whoever by act or omission causes damage to another, there being fault or negligence, is obliged to pay for the damage done.

  • Damnum absque injuria - damage without injury; principle that although there was physical damage, there was no legal injury, as there was no violation of a legal right.

  • Quasi-delict - a legal responsibility arising from an act or omission causing damage to another, there being fault or negligence; the defendant shall be liable for all damages which are the natural and probable consequences of the act or omission complained of, whether or not such damages have been foreseen or could have reasonably been foreseen.

CASE: NIED

No legal principles or doctrines can be identified from the provided text as it lacks discussion on the facts and issues of the case.