Facts:

• Spouses Jose and Virginia Fontanilla filed a suit against the National Irrigation Administration (NIA) and Honorable Inocencio D. Maliaman.
• The case arose from an incident where Hugo Garcia, a driver employed by NIA, negligently caused the death of Francisco Fontanilla, the son of the petitioners.
• The incident occurred along the Marikina National Road within the city limits of San Jose City.
• The lower court ruled in favor of the Fontanillas, holding NIA liable for damages.
• NIA, through the Solicitor General, filed a Motion for Reconsideration, arguing that it is a government agency performing governmental functions and should not be held liable for the tortious acts of its employees.
• The matter was elevated to the Supreme Court, which rendered a decision on February 27, 1991.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that the National Irrigation Administration (NIA) can be held liable for the damages caused by its employee, Hugo Garcia.
• The Court determined that the NIA...(Unlock)

Ratio:

• The Court examined the nature of NIA's functions and concluded that while NIA serves public welfare and public benefit, its primary aim is the irrigation of lands, which is a proprietary function.
• The Court cited various precedents and legal doctrines, including American jurisprudence on irrigation districts, which support the view that such entities perform proprietary functions.
• NIA is a government agency with a separate juridical personality, as established by its charter under Republic Act No. 3601 and Presidential Decree No. 552.
• This separate juridi...continue reading