Case Digest (G.R. No. 132540)
Facts:
This case involves a dispute between the petitioners, Albay Electric Cooperative, Inc. (ALECO), and its employees Edgardo A. San Pablo and Evan Calleja (collectively referred to as "petitioners"), against the private respondent, Mayon International Hotel, Inc. (MIH). The events leading to the case transpired on September 16, 1997, when ALECO employees, led by Calleja and other associates, were conducting a routine inspection of the electrical facilities at MIH. During the inspection, they discovered that the current transformer (CT) box preventing unauthorized access had been tampered with, and it was later revealed that such tampering allowed inaccurate recording of energy consumption. MIH subsequently filed a complaint on October 3, 1997, alleging damages due to illegal electric disconnection and extortion against ALECO. The case was docketed as Civil Case No. 9441 at the Regional Trial Court (RTC) of Legazpi City, under the jurisdiction of Judge Rafael P. Santelices
Case Digest (G.R. No. 132540)
Facts:
- Petitioners:
- ALBAY ELECTRIC COOPERATIVE, INC. (ALECO)
- Edgardo A. San Pablo
- Evan Calleja
- Respondents:
- Hon. Rafael P. Santelices, in his capacity as Presiding Judge of the Regional Trial Court (RTC) of Legazpi City, Branch No. 2
- Mayon International Hotel, Inc. (MIH)
- Initiation of the Case:
- MIH filed a Complaint on October 3, 1997, in Civil Case No. 9441 alleging damages due to illegal electric disconnection and extortion.
- MIH claimed that on September 16, 1997, ALECO employees tampered with the security seal, plastic seal, padlock, and sealing lead of the current transformer (CT) box, and then maliciously attributed the tampering to MIH to extort money.
- ALECO subsequently issued an undated, unsigned billing charging MIH a computed differential amount for electricity consumption allegedly violating Section 6 of Republic Act No. 7832.
Parties and Procedural Background
- MIH’s Allegation:
- ALECO employees intentionally tampered with the CT box and then falsely blamed MIH.
- The intent was to extort money from MIH using a unilateral computation of electricity consumption.
- Petitioners’ Version:
- On September 16, 1997, around 3:00 p.m., ALECO’s Head of the Task Force on Systems Loss Reduction, Evan Calleja, along with a group of ALECO personnel, conducted a routine inspection at MIH upon obtaining permission from the MIH engineering head, Conversion Lorica.
- During the inspection, it was noted that the padlock of the CT box had been tampered with.
- Calleja’s test on the electric meter revealed that the kilowatt-hour disk rotated in reverse, suggesting interference with the CT box wiring.
- On discovering tampering with the seals and padlock, Calleja immediately informed General Manager San Pablo, who then visited the site accompanied by an engineer and a police officer.
- Upon opening the CT box using a hack or steel saw (due to the padlock’s malfunction), ALECO personnel observed evidence of tampering including a cut lead seal and interchanged conductive lines resulting in manipulated meter readings.
Dispute on the Facts of the Incident
- Pre-Trial Conference Scheduling and Notice:
- Judge Santelices set a pre-trial conference on November 12, 1997, despite MIH not filing a corresponding motion or the last pleading being filed.
- Petitioners alleged that the schedule was fixed without due notification and in violation of Administrative Circular No. 20-95 and Section 1, Rule 18 of the 1997 Rules of Civil Procedure.
- Withdrawal of Counsel and Special Appearance:
- On November 11, 1997, petitioners’ counsel, Atty. Wilfredo Matias, filed a motion to withdraw, leaving petitioners unrepresented for the imminent pre-trial conference.
- Under pressing circumstances, petitioners secured Atty. Danilo V. Roleda as a special appearance solely to cancel the pre-trial conference, a move that was heavily contested by MIH’s counsel.
- Orders on Reimbursement of Expenses:
- Judge Santelices, after lengthy arguments, cancelled the scene pre-trial and rescheduled it to December 10, 1997.
- He ordered petitioners to reimburse MIH’s counsel P2,500.00 for transportation expenses and P3,000.00 for his court appearance fee incurred due to his attendance at the pre-trial conference.
- Motion for Reconsideration:
- Petitioners, through subsequent counsel, filed a Motion for Reconsideration of the reimbursement order.
- Judge Santelices denied the motion on February 11, 1998, reasoning that even if some error was present, the reimbursement should have been made payable to MIH rather than its counsel, and that petitioners’ last-minute notice contributed to the expenses incurred.
Issues with Lower Court Proceedings
- RTC Decision:
- The RTC rendered a decision on August 7, 2000, in favor of the petitioners, dismissing MIH’s complaint and awarding various damages and fees against MIH.
- The awards included differential billing damages, exemplary damages, moral damages, and attorney’s fees.
- Appeal to the Court of Appeals:
- MIH appealed the RTC decision, which led to the Court of Appeals modifying the award by reducing the actual damages to ALECO and deleting the awards for moral, exemplary damages, and attorney’s fees.
- The Court of Appeals rendered its decision on July 30, 2007, which became final and executory.
- Petition for Certiorari:
- ALECO, along with its co-petitioners, filed a Petition for Certiorari under Rule 65, challenging the interlocutory orders of Judge Santelices as being issued without or in excess of jurisdiction and with grave abuse of discretion.
- MIH later joined the petition by filing a Manifestation, effectively waiving any claim to the ordered reimbursement and affirming that the orders be declared null and void.
Subsequent Developments and Final Litigation
Issue:
- Whether Judge Santelices acted without or in excess of his jurisdiction or with grave abuse of discretion in setting the pre-trial conference on November 12, 1997, despite procedural irregularities such as the absence of a proper motion by MIH and compliance with Section 1, Rule 18 of the 1997 Rules of Civil Procedure.
Jurisdiction and Abuse of Discretion in Scheduling
- Whether Judge Santelices exceeded his jurisdiction or abused his discretion by issuing orders on November 12, 1997, and February 11, 1998, directing the petitioners to pay MIH’s counsel an amount of P2,500.00 for transportation and P3,000.00 for court appearance fee, especially given that petitioners had secured a special appearance merely to cancel the scheduled pre-trial.
Reimbursement Order Validity
- Whether ALECO’s direct resort to a Petition for Certiorari to challenge interlocutory orders — without first exhausting the remedies available in lower courts — was proper, considering the principle of hierarchy among courts.
Appropriateness of Direct Resort to Certiorari
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)