Case Summary (G.R. No. L-55273-83)
Relevant Facts and Procedural Background
The petitioners filed eleven separate but related complaints for damages against the NPC and its superintendent for the flood caused by the opening of the floodgates. The NPC filed separate answers to each complaint and asserted as a special affirmative defense that it could not be sued without the express consent of the State because it was performing a purely governmental function in operating the Angat Dam. On July 29, 1980, the Court of First Instance dismissed all complaints against the NPC, leaving only the superintendent as the defendant. The petitioners moved for reconsideration, which was denied on October 3, 1980, prompting the filing of the present petition for review on certiorari.
Court’s Order on the NPC’s Motion to Dismiss
The December 21, 1979 order of the trial court dismissed the cases against NPC on the ground that the corporation was performing a purely governmental function concerning the operation of the Angat Dam and, as such, could not be held liable in tort without express State consent. The petitioners opposed this motion, citing Section 3(d) of Republic Act No. 6395 (the NPC Charter), which provides that NPC may "sue and be sued in any court," but the court limited this provision to corporate or contractual matters, excluding tort claims.
Issues Presented
The Supreme Court identified two central issues:
- Whether the National Power Corporation performs a governmental function in managing and operating the Angat Dam; and
- Whether the NPC’s power to sue and be sued under its organic charter extends to liability for tortious acts, such as those alleged by the petitioners.
Legal Analysis and Ruling on Governmental versus Proprietary Function
The Court discussed that the NPC is a government-owned and controlled corporation (GOCC) with a separate legal personality distinct from the government itself. It noted that the government has injected capital into NPC and allowed it to sue and be sued. The Court declined to engage in an elaborate discussion on whether the operation of the Angat Dam is a governmental or proprietary function, emphasizing instead that the NPC’s charter unequivocally allows it to be sued in any court, with no exceptions or qualifications related to the nature of the cause of action.
Interpretation of NPC’s Power to Sue and Be Sued
The Court emphasized that Section 3(d) of Republic Act No. 6395 must be given its plain and unequivocal meaning. The specific provision states that NPC may sue and be sued "in any court," a phrase that is not limited or qualified with respect to types of actions, including tort claims. Accordingly, the NPC cannot assert immunity from suit based solely on the nature of its functions or the type of claim raised against it. The legal personality granted to NPC ensures accountability and allows private citizens, such as the petitioners, to seek redress for damages caused.
Final Resolution and Court’s Order
The Supreme Court granted the petition, setting aside the trial court’s orders dismissing the complaints and denying the motions for reconsideration. The Court ordered the reinstatement of the petitioners’ complaints against the NPC, mandating that the trial court proceed to hear the ca
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Case Syllabus (G.R. No. L-55273-83)
Facts of the Case
- On October 26, 1978, during Typhoon "KADING," the National Power Corporation (NPC), through its plant superintendent Benjamin Chavez, simultaneously opened all three floodgates of the Angat Dam.
- This sudden and simultaneous opening caused flooding in several towns in Bulacan, especially Norzagaray, which suffered extensively.
- Approximately a hundred residents in Norzagaray died or were reported dead; properties worth millions of pesos were destroyed or washed away.
- The flood was unprecedented and directly linked to the actions of NPC.
- The petitioners, victims of the flood, filed eleven separate complaints for damages against NPC and its plant superintendent, docketed under Civil Cases Nos. SM-950, 951, 953, 958, 959, 964, 965, 966, 981, 982, and 983.
- Despite separate filings, all complaints shared a common cause of action stemming from the flood and its effects.
Procedural History
- NPC answered each complaint, denying allegations and filing counterclaims for damages.
- NPC invoked a special and affirmative defense claiming that it was performing a "purely governmental function" in managing the Angat Dam; thus, it argued it could not be sued without the State's express consent.
- A preliminary hearing was held focusing on NPC’s affirmative defense, equivalent to a motion to dismiss.
- Petitioners opposed the motion, arguing NPC was performing proprietary functions, supported by Section 3(d) of Republic Act No. 6395, which states NPC can sue and be sued in any court.
- On December 21, 1979, the Court of First Instance of Bulacan dismissed all complaints against NPC, leaving only the superintendent, Benjamin Chavez, as defendant.
- Petitioners filed a motion for reconsideration on August 7, 1980, which was denied on October 3, 1980.
- Petitioners elevated the case through a petition for review on certiorari under Republic Act No. 5440.
Key Legal Issues
- Whether the National Power Corporation performs a governmental function in the management and operation of the Angat Dam.
- Whether the power of NPC to sue and be sued under its organic charter includes the power to be sued for tort claims.
Arguments Presented
- NPC's Position:
- NPC contended that operating the Angat Dam is a purely governmental function and that it cannot be held lia