Fontanilla vs Maliaman
94 SCRA 486
FACTS:
National Irrigation Administration (NIA), a government agency, was held liable for damages resulting to the
death of the son of herein petitioner spouses caused by the fault and/or negligence of the driver of the said agency.
NIA maintains that it is not liable for the act of its driver because the former does not perform primarily proprietorship
functions but governmental functions.
ISSUE:
Whether or not NIA may be held liable for damages caused by its driver.
HELD:
Yes. NIA is a government agency with a corporate personality separate and distinct from the government,
because its community services are only incidental functions to the principal aim which is irrigation of lands, thus,
making it an agency with proprietary functions governed by Corporation Law and is liable for actions of their
employees.