Case Digest (A.M. SDC-97-2-P) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In National Power Corporation, et al. v. Court of Appeals, et al. (294 Phil. 415, May 21, 1993), private respondents led by Gaudencio C. Rayo, Bienvenido P. Pascual and others filed four separate complaints in the Court of First Instance (Branch 5, now Regional Trial Court) of Bulacan against petitioners National Power Corporation (NPC) and its plant supervisor Benjamin Chavez. They alleged that on October 26–27, 1978, petitioners negligently released large volumes of water through three spillways of the Angat Dam in Norzagaray, Bulacan, after typhoon “Kading” raised the reservoir above its safe maximum headwater elevation. This sudden discharge allegedly caused a flash flood that drowned people, washed away livestock, and destroyed properties of households along the Angat River. NPC denied negligence, asserted it exercised due diligence, sent warnings to municipalities on October 24, 1978, and invoked force majeure. The trial court dismissed the complaints for lack of credible Case Digest (A.M. SDC-97-2-P) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Origin of the Action
- Four separate complaints for damages were filed between December 1978 and January 1982 by residents of Norzagaray, Bulacan against National Power Corporation (NPC) and its plant supervisor, Benjamin Chavez.
- Plaintiffs alleged that on 26–27 October 1978, despite knowledge of the approaching Typhoon “Kading,” defendants failed to monitor the Angat Dam’s reservoir level and negligently opened three spillways, causing sudden release of water that inundated homes, drowned persons and animals, and destroyed property.
- Defendants’ Pleadings and Special Defenses
- NPC and Chavez contended they exercised due care and prudence in dam operation, sent written warnings to local municipalities, and released water only to prevent dam collapse.
- They pleaded force majeure (act of God) and damnum absque injuria, and advanced a special defense that NPC, performing a governmental function, could not be sued in tort.
- Trial Court Proceedings
- On preliminary hearing, the trial court dismissed the complaints against NPC for lack of tort liability under its charter, a ruling later reversed by the Supreme Court to reinstate the action.
- After consolidation, the Regional Trial Court dismissed all complaints for “lack of sufficient and credible evidence.”
- Court of Appeals Decision
- On 19 August 1991, the Court of Appeals reversed the RTC, finding a “patent gross and evident lack of foresight, imprudence and negligence” by NPC and Chavez in dam management.
- It awarded actual and moral damages, litigation expenses, and attorney’s fees against the petitioners, holding their written warning of 24 October 1978 insufficient and rejecting the force majeure defense.
- Supreme Court Review
- Petitioners filed a Rule 45 petition raising: the applicability of Juan F. Nakpil & Sons v. CA; adequacy of warnings; characterization of damages as damnum absque injuria; and their entitlement to attorneys’ fees on counterclaim.
- On 21 May 1993, the Supreme Court dismissed the petition and affirmed the Court of Appeals decision with costs.
Issues:
- Did the Court of Appeals err in applying the Nakpil & Sons act-of-God doctrine and in finding petitioners negligent?
- Were the 24 October 1978 written warnings sufficient to exonerate petitioners from liability?
- Were the damages suffered by private respondents merely damnum absque injuria?
- Did the Court of Appeals err in denying petitioners’ counterclaim for attorneys’ fees and litigation expenses?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)