Case Summary (G.R. No. 102206)
Overview of Claims
The private respondents allege significant damages to their properties due to the flooding. The damages claimed by individuals were as follows: Lauro Palad - ₱42,500.00; Jose Palad - ₱59,900.00; Domingo Cruz - ₱25,000.00; Emilia Mariano - ₱9,500.00; Raymundo Palad - ₱19,000.00; and Francisco Torres - ₱18,000.00, totaling substantial financial losses for the respondents. These claims lead to the filing of an action for damages on October 25, 1982, in the Regional Trial Court (RTC) of Malolos, Bulacan.
Petitioners' Defense
In their response, the petitioners contended that they exercised due care and put necessary precautions in place in anticipation of the typhoon. They claimed to have provided timely warnings to nearby towns the morning prior to the flooding and argued that the flooding resulted from force majeure, asserting that no causal relationship existed between their actions and the damages experienced by the respondents. The petitioners also raised defenses of damnum absque injuria (damage without injury) and laches, arguing that the plaintiffs had sufficient opportunity to mitigate damages.
RTC Decision
On June 18, 1990, the RTC ruled in favor of the private respondents. It ordered the petitioners to pay specified actual damages, ₱30,000.00 each in moral damages, and 25% of any collected amount as attorney's fees. The judgment emphasized the petitioners' negligence, especially their decision to abruptly open the spillway gates at midnight, which contributed to the flooding.
Court of Appeals Ruling
The petitioners appealed to the Court of Appeals, which affirmed the RTC's decision on August 16, 1991. The appellate court found the petitioners negligent for their failure to anticipate the storm effectively and for delaying the gradual opening of the spillway gates. It also confirmed that the negligence of the petitioners was a proximate cause of the damage, even if the flooding coincided with an act of God (the typhoon).
Petition for Review
The petitioners sought a review of the appellate court's ruling, raising similar defenses as in previous cases and asserting that they should not be held liable due to the force majeure of the typhoon. They insisted that their pre-typhoon warnings provided immunity from liability and that damages suffered by the respondents fell under the principle of damnum absque injuria.
Supreme Court Decision
The Supreme Court ruled on June 25, 1993, reaffirming the findings of negligence on the part of the petitioners. The court stated that the petitioners could not invoke force majeure to escape liability due to the concurrent human factor of negligence. The decision upheld the appellate court's findings and emphasized that the petitioner’s late action of opening the
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Background of the Case
- This case arises from prior decisions involving the National Power Corporation (NPC) regarding the inundation of towns near the Angat Dam during Typhoon "Kading" on October 26-27, 1978.
- The petitioners, NPC and Benjamin Chavez, were found negligent in previous rulings, leading to damages suffered by private respondents, who are landowners in Bulacan.
- The private respondents claimed damages amounting to various sums due to the flooding, which was attributed to the negligence of the petitioners.
Parties Involved
- Petitioners: National Power Corporation and Benjamin Chavez
- Respondents: Lauro Palad, Jose Palad, Domingo Cruz, Emilia Mariano, Raymundo Palad, and Francisco C. Torres
Nature of the Complaint
- The private respondents filed an action for damages against the petitioners on October 25, 1982, after their claims for compensation were rejected.
- The case was filed in the Regional Trial Court (RTC) of Malolos, Bulacan, and was assigned as Civil Case No. SM-1338.
Claims for Damages
- The specific claims for damages from each respondent included:
- Lauro Palad: P42,500.00
- Jose Palad: P59,900.00
- Domingo Cruz: P25,000.00
- Emilia Mariano: P9,500.00
- Raymundo Palad: P19,000.00
- Francisco Torres: P18,000.00
Petitioners' Defense
- In their answer, the petitioners asserted that they had taken precautions for the typhoon and claimed to have sent out early warnings.
- They invoked the defense of force majeure and argued that there was no causal relationship between their actions and the damages claimed.
- The petitioners also contended that the plaintiffs h