Sanggacala v. National Power Corporation

 

Sanggacala v. National Power Corporation

G.R. No. 209538

July 7, 2021

 

FACTS:

The National Power Corporation (NAPOCOR) was tasked with the preservation of Lake Lanao Watershed and the installation of benchmarks around the lake to prohibit cultivation below the elevation of 702 meters. In 1978, NAPOCOR constructed the Agus Regulation Dam in Marawi City to control Lake Lanao's water outflow and generate power through hydroelectric plants along the Agus River. Sanggacala and others residing along the lake, filed complaints against the NAPOCOR, alleging that the refusal to open the dam's floodgates during flooding in various years caused damage to their farmlands and crops. The RTC ruled in favor of Sanggacala, finding that their properties were indeed damaged due to the NAPOCOR’s actions.However, the CA reversed the RTC Decision, stating that Sanggacala failed to establish a prima facie case for damages. The petitioners argued that the construction of the Agus Regulation Dam altered Lake Lanao's water level, causing floods that destroyed their farmlands and crops in multiple years. They claimed damages for the periods when the dam became operational. NAPOCOR, in its defense, denied liability for environmental tort based on negligence, asserting that it adhered to its duties under Memorandum Order No. 398 and was not at fault or negligent.

ISSUE:

Whether or not the principle of damnum absque injuria is applicable in this case.

RULING:

No. In order that a plaintiff may maintain an action for the injuries of which he complains, he must establish that such injuries resulted from a breach of duty which the defendant owed to the plaintiff — a concurrence of injury to the plaintiff and legal responsibility by the person causing it. The underlying basis for the award of tort damages is the premise that an individual was injured in contemplation of law. Thus, there must first be the breach of some duty and the imposition of liability for that breach before damages may be awarded; it is not sufficient to state that there should be tort liability merely because the plaintiff suffered some pain and suffering. The law affords no remedy for damages resulting from an act which does not amount to a legal injury or wrong. In this case, the SC stated that the flooding in the neighboring properties of the dam happened because of care on the part of NAPOCOR to maintain the water level of the dam within the benchmarks at the maximum normal lake elevation of 702 meters. Moreover, as to the second duty of the NAPOCOR to install benchmarks, the CA noted that it was only after many years from the time the dam was built that NPC installed said benchmarks. At that time, many farms and houses were already swamped and many fishponds, including those of the private respondents, were damaged. In addition, the SC already found in the 2005 NAPOCOR case that the principle of damnum absque injuria inapplicable, because NAPOCOR’s negligence due to its inability to maintain the level of water in its dams was satisfactorily and extensively established. Similarly, having established respondent's negligence in its failure to observe its legal mandate, the principle of damnum absque injuria finds no application here.