Title
City of Manila vs. Manila Electric Railroad and Light Co.
Case
G.R. No. 7627
Decision Date
Nov 30, 1912
The City of Manila sued Manila Electric Railroad and Light Company to recover fees for testing electric meters. The Supreme Court ruled the city had authority to impose reasonable fees under its charter and police powers, affirming the P2 per meter fee as lawful under Ordinance No. 68.
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Case Digest (G.R. No. 7627)

Facts:

  1. Parties Involved:

    • Plaintiff and Appellee: City of Manila
    • Defendant and Appellant: Manila Electric Railroad and Light Company
  2. Nature of the Case:

    • The City of Manila filed a lawsuit against the Manila Electric Railroad and Light Company to recover fees for inspecting and testing 2,712 electric meters prior to their installation. The fee charged was P2 per meter, totaling P4,483.90, with a credit of P1,085.10 for electric current furnished by the company to the city laboratory during the tests.
  3. Defenses Raised by the Defendant:

    • The city lacked authority to charge for testing the company's meters.
    • The fee of P2 per meter was excessive and illegal.
    • The ordinance relied upon by the city (Ordinance No. 68) did not authorize or prescribe fees for the type of testing conducted.
  4. Legal Basis for the City's Claim:

    • The city relied on its charter and police powers to enact ordinances for the inspection and testing of electric meters, including the imposition of reasonable fees for such services.

Issue:

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Ruling:

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Ratio:

  1. Authority of the City to Impose Fees:

    • The court held that the city's charter granted it the power to regulate and inspect electric meters, and this authority implicitly included the power to impose reasonable fees for such services. The absence of an express prohibition in the charter did not negate this authority.
  2. Reasonableness of the Fee:

    • The court deferred to the trial judge's conclusion that the fee of P2 per meter was not proven to be excessive or unreasonable. Judicial authority to declare an ordinance unreasonable must be exercised cautiously, and the evidence presented by the appellant was insufficient to overturn the lower court's finding.
  3. Applicability of Ordinance No. 68:

    • The court interpreted Ordinance No. 68 as authorizing fees for all types of meter testing, not just those under specific sections. The language of the ordinance was general and applicable to all inspections and tests conducted under its authority.
  4. Franchise and Tax Implications:

    • The court rejected the defendant's argument that the fee impaired its franchise, holding that the charge was not a tax but a reasonable fee for services rendered. The franchise's exemption from taxes did not apply to fees for specific services like meter testing.


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