Title
Supreme Court
Dela Cruz vs. Manila Electric Co.
Case
G.R. No. 197878
Decision Date
Nov 10, 2020
Residents challenged MERALCO’s high-voltage transmission lines near their homes, alleging health risks and environmental harm. The Supreme Court denied their petition, ruling insufficient evidence of ecological damage or unlawful acts, upholding public interest in air travel.

Case Digest (G.R. No. 197878)
Expanded Legal Reasoning Model

Facts:

  • Petitioners and Respondents
    • Petitioners: Residents of Barangay 183, Zone 20, Villamor, Pasay City and adjacent Magallanes Village, Makati City.
    • Respondents: Manila Electric Company (MERALCO); Barangay Chairman Cesar S. Toledanes and members of the Barangay Council of Brgy. 183; Manila International Airport Authority (MIAA).
  • NAIA III Power Supply and MERALCO Works
    • In 2001, the Philippine International Air Terminals Co., Inc. (PIATCO) applied to MERALCO for electricity for NAIA III; a nearby substation was constructed in 2002 and a transmission‐line route chosen through Brgy. 183.
    • MERALCO commenced excavation on September 10, 2009; Pasay City issued a cease-and-desist on December 3, 2009; Branch 118 RTC granted a preliminary mandatory injunction on July 23, 2010; works resumed and transmission lines carrying 115 kV were completed on November 19, 2010.
  • Procedural History
    • December 4, 2009: Residents filed a prohibitory injunction in RTC Branch 111; August 2010: Branch 111 declared the case moot after Branch 118’s injunction;
    • December 2010: Petitioners filed a writ of kalikasan petition in the Court of Appeals (CA); January 20, 2011: CA denied it for lack of merit; July 14, 2011: CA denied reconsideration; August 16, 2011: Petition for review on certiorari filed with the Supreme Court.

Issues:

  • Forum Shopping
Did petitioners improperly pursue multiple remedies on the same facts?
  • Violation of Right to a Balanced and Healthful Ecology
Does the installation of high-voltage transmission lines near residences infringe the constitutional ecology right?
  • Precautionary Principle
Should the precautionary principle be invoked given scientific uncertainty on health risks from electromagnetic fields?

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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