Fontanilla vs Maliaman

Facts: A pick up owned by the National Irrigation Administration and driven officially by its regular driver,
Hugo Garcia, bumped a bicycle ridden by Francisco Fontanilla, which resulted in the latter's death. The
parents of Francisco filed a suit for damages against Garcia and the NIA, as Garcia's employer. After trial,
the court awarded actual, moral and exemplary damages to Spouses Fontanilla. NIA appealed. The
Solicitor General contends that the NIA does not perform solely and primarily proprietary functions but is
an agency of the government tasked with governmental functions, and is therefore not liable for the
tortious act of its driver Hugo Garcia, who was not its special agent.

Issue:

May NIA, a government agency, be held liable for the damages caused by the negligent act of its driver
who was not its special agent?

Ruling:

Yes. NIA is a government agency with a juridical personality separate and distinct from the government. It
is not a mere agency of the government but a corporate body performing proprietary functions. Therefore,
it may be held liable for the damages caused by the negligent act of its driver who was not its special
agent.