Gov't instrumentality need not be economically viable

The Philippine Reclamation Authority (PRA) was created essentially to perform a public service considering that it was primarily responsible for a coordinated, economical and efficient reclamation, administration and operation of lands belonging to the government with the object of maximizing their utilization and hastening their development consistent with the public interest. xxx

In contrast, government instrumentalities vested with corporate powers and performing governmental or public functions need not meet the test of economic stability. These instrumentalities perform essential public services for the common good, services that every modern state must provide its citizens. These instrumentalities need not be economically viable since the government may even subsidize their entire operation. These instrumentalities are not the “government-owned or controlled corporations” referred to in Section 16, Article XII of the 1987 Constitution.” (Republic vs. City of Parañaque; G.R. No. 191109, 2012)