Sanggacala vs. National Power Corporation, G.R. No. 209538 (Philippines)

The National Power Corporation (NPC) constructed the Agus Regulation Dam for control and management of Lake Lanao's water outflows and to run the turbine machines for power production of its hydroelectric power plants along the Agus RIver. Petitioners, whose farmlands are located along the Lake Lanao shore, claim their crops were damaged by flooding for several years due to NPC's refusal to open the floodgates of Agus Regulation Dam. Petitioners cite a study showing that Lake Lanao should have a lower maximum elevation contrary to a government Letter of Instruction which NPC follows. NPC, on the other hand, argued that this is a case of damnum absque injuria since there was no actionable injury to petitioners.

Disposing of the petition, the court held that tort law can be used to address environmental harms to a well-defined area or specific person, or a class of persons, when readily supported by general and specific causation and if the case closely fits the elements of a tort cause of action. An environmental tort is a hybrid of tort law and environmental law. Environmental laws are concerned with the prevention or correction of environmental harm, while tort laws are principally concerned with righting a wrong. The court said that the principle of damnum absque injuria does not apply because NPC was negligent in its inability to maintain the water level. Actual and compensatory damages were awarded to the petitioners.