National Power Corporation v. Dardagan Pangaga

Summary

The Supreme Court denied NPC's petition challenging lower courts' findings of liability for flood damages to respondent's quarry land caused by negligent operation of the Agus Regulation Dam from 1979-2004. The Court applied Article 2176 (quasi-delict) and the res ipsa loquitur doctrine, finding NPC presumptively negligent for disrupting the natural water flow from Lanao Lake to Agus River through dam operations. Despite NPC's claims of compliance with water level requirements under Memorandum Order No. 398, the Court found preponderant evidence of negligence when benchmarks were submerged during floods. The Court rejected prescription and laches defenses as improperly raised, noting respondent's vigilant assertion of rights since discovering the dam's role in 1994. The decision affirmed the CA's award of P2.5 million temperate damages plus moral, exemplary damages and attorney's fees, modifying only the interest rate to 6% per annum. The case established important precedent on government corporation liability for infrastructure-related property damage.