National Power Corporation v. The Honorable Court of Appeals (Ninth Division)

Summary

The Supreme Court affirmed the liability of the National Power Corporation (NPC) for damages to private respondents' fishponds caused by flooding at Lake Lanao in 1986. The Court found NPC negligent in performing two key duties under Presidential Memorandum Order No. 398: maintaining the lake's maximum water level at 702 meters and installing warning benchmarks. Despite NPC's claims that water levels never exceeded 702 meters, the courts found that benchmarks were submerged during ocular inspection, proving flooding occurred. The Court applied the res ipsa loquitur doctrine and Article 2176 of the Civil Code on quasi-delicts, rejecting NPC's defenses of fortuitous events and damnum absque injuria. Since actual damages could not be proven with certainty, the Court awarded temperate damages totaling P710,000 plus litigation expenses, emphasizing that government corporations are not exempt from tort liability when their negligence causes private property damage.