Title
ATP Technologies International, Inc. vs. Micron Precision Phils., Inc.
Case
G.R. No. 171102
Decision Date
Nov 24, 2006
ATP failed to prove Micron tampered with the sub-meter or owed unpaid electrical bills; Court ordered ATP to refund Micron's security deposit with interest and attorney's fees.
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Case Digest (G.R. No. 171102)

Facts:

Lease and Sublease Agreement

  • Petitioner ATP Technologies International, Inc. (ATP) was the lessee of a factory/office building owned by Ecozone Properties in Cabuyao, Laguna.
  • On January 14, 1999, ATP sublet a portion of the premises to respondent Micron Precision Philippines, Inc. (Micron) for one year. The sublease contract was renewed twice in 2000 and 2001.
  • The sublease contract required Micron to provide a security deposit, which was to be returned within 30 days after the expiration of the contract, provided Micron vacated the premises satisfactorily and settled all liabilities.

Pre-termination of Lease

  • In June 2000, Ecozone Properties pre-terminated its lease with ATP due to ATP's failure to pay rent. ATP's properties were attached, and Micron was directed to pay rent directly to Ecozone Properties.
  • Micron's sublease with ATP was pre-terminated on June 1, 2001.

Dispute Over Security Deposit

  • In August 2001, Micron vacated the premises and demanded the refund of its security deposit. ATP refused, claiming Micron had unsettled liabilities, including alleged tampering with its electric sub-meter in 1999, resulting in a billing deficiency of P102,827.85.
  • ATP requested an investigation by the San Fernando Electric Light and Power Company, Inc. (SFELPCO), which found that the sub-meter was not properly secured and suggested a possibility of pilferage. ATP claimed Micron owed P911,250.00 for underpaid electrical bills and P236,250.00 for unpaid consumption from June to August 2001.

Trial Court Decision

  • The Regional Trial Court (RTC) ruled in favor of ATP, holding that Micron tampered with its sub-meter and failed to pay its electric bills. The court ordered Micron to pay ATP P505,494.00 in actual damages, P100,000.00 in exemplary damages, and P50,000.00 in attorney's fees.

Court of Appeals Decision

  • The Court of Appeals reversed the RTC decision, ordering ATP to refund Micron's security deposit of P642,006.00, plus interest, attorney's fees, and costs of suit. The appellate court found that ATP failed to prove Micron tampered with the sub-meter or owed unpaid electrical bills.

Issue:

  1. Whether the Court of Appeals erred in reversing the RTC decision and ordering ATP to refund Micron's security deposit despite evidence of Micron's alleged unpaid electrical consumption.
  2. Whether the Court of Appeals erred in awarding damages and attorney's fees to Micron.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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