G.R. No. 125018 - Remman Enterprises, Inc. vs. Court of Appeals

Remman Enterprises, Inc. (REMMAN) and Crispin E. Lat are adjoining landowners in Barangay Bugtong Na Pulo, Lipa City.
Lat’s land is agricultural with an area of 1.8 hectares, planted mostly with fruit trees.
REMMAN’s land covers fifteen (15) hectares; six (6) hectares are used for a piggery business.
REMMAN’s land is approximately one and a half (1.5) meters higher in elevation compared to Lat’s property.

In July 1984, Lat noticed REMMAN’s waste disposal lagoon overflowing and flooding about one-fourth (1/4) of his plantation.
The overflow consisted of water contaminated with pig manure, making the soil acidic, malodorous, and polluted.
The flooded portion of the plantation, nearly one (1) hectare, suffered damage affecting various fruit trees; the trees withered and died.
Lat made repeated representations to REMMAN which were ignored.
On March 14, 1985, Lat filed a complaint for damages and sought a preliminary mandatory injunction against REMMAN.

REMMAN denied the allegations and claimed it had taken measures such as constructing additional lagoons to contain wastewater.
After conducting an ocular inspection and evaluating evidence, the Regional Trial Court (RTC) found that REMMAN’s lagoon overflowed, flooding Lat’s plantation with ankle-deep contaminated water from June 1984 to March 1985.
The flood destroyed one jackfruit tree, fifteen coconut trees, 122 coffee trees, and an unspecified number of mango trees, bananas, and vegetables.
The RTC ordered REMMAN to pay Lat P186,975.00 as compensation for lost profits over three crop years and P30,000.00 as attorney’s fees.

The Court of Appeals (CA) affirmed the RTC's decision in toto.
CA held that REMMAN was negligent and that the overflow directly caused the damage.
The negligence was attributed to:

Failure to monitor lagoon water levels before, during, and after heavy rains;
Failure to augment existing lagoons despite increased piggery capacity (11,000 heads);
Failure to comply with promises to prevent damage.

REMMAN filed a Petition for Review on Certiorari, challenging the factual findings on several grounds including speculation, misapprehension of facts, grave abuse of discretion, and incomplete consideration of relevant evidence.
REMMAN also contested the failure of courts to compel production of Lat’s income tax returns and alleged that damages were not satisfactorily established.
REMMAN claimed that any damage was due to a fortuitous event (heavy rains) and invoked the natural easement principle for the flow of water from higher to lower estates.

Whether REMMAN was negligent and liable for the damages caused by the overflow of piggery waste water to Lat’s plantation.
Whether the denial of REMMAN’s request for the production of Lat’s income tax returns was proper.
Whether the damages awarded to Lat were reasonably established and supported by evidence.
Whether the damages were due to a fortuitous event (act of God), thereby exempting REMMAN from liability.
Whether REMMAN could rely on the natural easement doctrine to justify the flow of contaminated water onto Lat’s property.