Case Summary (G.R. No. 209538)
Key Dates
• 1973: Memorandum Order No. 398 reserves lakeshore areas below 702 m elevation and mandates installation of benchmarks.
• 1978: NPC constructs Agus Regulation Dam.
• 1979–1996: Years in which petitioners suffered crop and property damage.
• December 12, 2005: RTC issues joint judgment awarding damages to petitioners.
• March 26, 2013: Court of Appeals reverses RTC.
• July 7, 2021: Supreme Court renders decision under the 1987 Constitution.
Applicable Law
• 1987 Philippine Constitution – property rights, due process, state duties.
• Commonwealth Act No. 120 (as amended) and Republic Act No. 6395 – NPC’s mandate and powers.
• Memorandum Order No. 398 (1973) – lake elevation ceiling and benchmark requirements.
• Civil Code Articles on quasi-delict (Art. 2176), damnum absque injuria, exemplary and moral damages (Arts. 2217, 2231), attorney’s fees (Art. 2208), interest (Art. 2211).
• Rules of Court on res judicata (Rule 39, Sec. 47), proof by preponderance (Rule 133), and petitions for review (Rule 45).
Procedural History
- Petitioners filed separate damage suits in 1995–1996, later consolidated.
- RTC (Dec. 12, 2005) found NPC negligent for failing to open floodgates and maintain benchmarks, awarded actual, moral, exemplary damages, just compensation, rental, attorney’s fees, interest.
- Court of Appeals (Mar. 26, 2013) held petitioners failed to establish prima facie case and reversed.
- Supreme Court granted certiorari, deliberated issues of res judicata, environmental tort, causation, damages.
Issues Presented
- Applicability of res judicata by conclusiveness of judgment.
- NPC’s liability for environmental tort based on negligence.
- Proof of damages by preponderant evidence.
- Application of damnum absque injuria doctrine.
- Correct measure and entitlement to various damages.
Res Judicata and Conclusiveness of Judgment
• Bar by prior judgment precludes same cause of action; conclusiveness precludes re-litigation of issues necessarily decided.
• Identity of parties and issues required; substantial identity or privity.
• 2005 case involved different petitioners, properties, periods; no privity or identity of subject matter.
• Conclusiveness doctrine inapplicable.
Environmental Tort and Negligence
• Quasi-delict under Art. 2176 and tort principles overlap to redress direct environmental harms.
• Elements: duty, breach (fault/negligence), damage, and proximate cause.
• NPC’s duties under MO 398: maintain lake ≤ 702 m and erect/maintain benchmarks.
• Jurisprudence: earlier Angat Dam cases (1988, 1992–1993, 2005) held NPC liable for negligent dam operations causing flooding.
• Trial court’s findings of negligence based on absence of flooding pre-dam construction, admission of damage by NPC payments, failure to inform or install benchmarks timely, and res ipsa loquitur.
Causation and Damnum Absque Injuria
• Petitioners demonstrated general and specific causation: NPC’s operation of dam directly raised water levels and inundated properties.
• Damnum absque injuria inapplicable once a legal duty under MO 398 is breached and negligence is established.
Proof and Assessment of Damages
• Standards: preponderance of evidence, respect for trial court’s credibility assessments.
• Actual da
Case Syllabus (G.R. No. 209538)
Facts
- National Power Corporation (NPC), a government-owned and controlled corporation under Commonwealth Act No. 120 (as amended), is mandated to develop hydroelectric power and manage water sources nationwide.
- In 1973, Memorandum Order No. 398 required NPC to maintain Lake Lanao’s maximum elevation at 702 meters and to install benchmarks warning against cultivation below that level.
- In 1978 NPC constructed the Agus Regulation Dam at Saduc, Marawi City to regulate Lake Lanao’s outflow and supply water to downstream hydroelectric plants (Agus I, II, IV, VI, VII and VIII).
- Petitioners are members of the Ranao-NPC Affected Organization—farmers and fishpond owners along Lake Lanao’s shore.
- From 1979 to 1996, petitioners’ farmlands and crops were repeatedly flooded. They allege NPC’s refusal to open the dam’s floodgates during overflooding caused these damages.
- NPC admitted paying some claimants for 1993–1994 flooding, but contends petitioners’ improvements were below 702 m in violation of MO 398 and that any flooding was damnum absque injuria.
Procedural History
- Petitioners filed separate complaints for damages before RTC Marawi City (Civil Cases Nos. 1322-95, 1332-95, 1355-95, 1361-95).
- On December 12, 2005, the RTC rendered a Joint Judgment in favor of petitioners, awarding actual, moral, exemplary damages, attorney’s fees, just compensation, rental and interest.
- NPC appealed to the Court of Appeals.
- On March 26, 2013, the CA reversed the RTC judgment, holding petitioners failed to establish a prima facie case and discrediting the Washburn study as hearsay.
- CA denied petitioners’ motion for reconsideration on September 16, 2013.
- Petitioners filed a Petition for Review on Certiorari under Rule 45 before the Supreme Court on December 4, 2013.
Issues
- Whether the doctrine of conclusiveness of judgment (res judicata) applies by reference to National Power Corporation v. Court of Appeals (2005).
- Whether NPC committed an environmental tort based on negligence in operating