National Power Corporation v. The Court of Appeals

Summary

This case involves liability for flooding damage caused by the operation of Angat Dam during Typhoon Kading in 1978. Private respondents sued National Power Corporation and its Plant Superintendent for damages after massive flooding destroyed their properties when all three dam floodgates were suddenly opened without adequate warning. The Supreme Court affirmed lower court decisions awarding damages, ruling that despite the typhoon being an act of God, NPC's negligence in suddenly opening floodgates after maintaining maximum water levels and providing inadequate warnings constituted the proximate cause of damage. The Court applied quasi-delict liability under Civil Code Article 2176, establishing that negligence concurrent with force majeure does not exempt liability. The decision reinforced that government corporations must exercise due diligence in operating public utilities to prevent foreseeable harm to citizens.