National Irrigation… · G.R. 73919

Petitioner: National Irrigation Administration
Respondent: The Honorable Intermediate Appellate Court
Citation: G.R. No. 73919
Court: Supreme Court
Division: Second Division
Ponente: Nocon, J.
Decided: September 18, 1992

Summary

The Supreme Court affirmed lower courts' ruling holding the National Irrigation Administration liable for quasi-delict damages caused by negligent construction of irrigation canals. NIA built irrigation facilities in 1967 without proper safety measures like check gates and drainage systems, causing continuous flooding of private respondents' rice lands for nearly seven years. The Court established that NIA, despite being a government agency, has separate juridical personality and can be sued under P.D. No. 552. The negligence was proven through testimonial evidence showing substantial crop losses. The Court applied Civil Code provisions on quasi-delict, rejecting NIA's immunity defense and affirming the award of P35,000 in damages plus attorney's fees, though reducing liability considering natural calamities and irrigation benefits received.

Statutes applied

Civil Code, Art. 2176

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By the Intellegal Editorial Board · September 18, 1992

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