Case Digest (G.R. No. 152769)
Facts:
Manila Electric Company v. Ma. Victoria Jose, G.R. No. 152769, February 14, 2007, Supreme Court Third Division, Austria‑Martinez, J., writing for the Court. The Third Division (Ynares‑Santiago, Chairperson; Callejo, Sr.; Chico‑Nazario, JJ., concurring; Nachura, J., on leave) decided the case.Ma. Victoria D. Jose (Victoria) was a longstanding MERALCO customer (Account No. 14419-2260-23; Meter No. 31D551-57) at a New Manila, Quezon City residence. On July 14, 1995 MERALCO Polyphase Inspector Santiago Inoferio inspected Victoria’s meter and issued a Service Inspection Report indicating burned insulation of a bushing current transformer (BCT) and a non‑polarity terminal; he recommended billing adjustment and record update. On October 3, 1995 MERALCO issued a differential adjustment billing for P232,385.20, explaining that the meter allegedly registered only 50% of actual consumption from January 29, 1993 to July 4, 1995. Victoria asked for reconsideration on October 27, 1995, contending the defect was fortuitous and due to MERALCO negligence; MERALCO countered by furnishing test reports and offering installment payments.
Victoria refused to pay; MERALCO sent an Overdue Account Notice (expiration date November 24, 1995). Victoria then filed in the Regional Trial Court (RTC), Branch 223, Quezon City, a Complaint for Injunction with Damages and sought a TRO and preliminary injunction. The RTC issued a TRO and a writ of preliminary injunction on January 22, 1996. After trial, the RTC rendered judgment on June 1, 1999 permanently enjoining MERALCO from collecting the P232,385.20 differential billing or disconnecting service, and awarding moral damages P500,000; exemplary damages P500,000; attorneys’ fees P100,000; and costs.
MERALCO appealed to the Court of Appeals (CA) in CA‑G.R. CV No. 63590. The CA, in a March 26, 2002 Decision, affirmed the RTC. MERALCO then filed a Petition for Review on Certiorari under Rule 45 to the Supreme Court, raising two grounds: (A) the CA gravely abused its discretion in holding MERALCO liable for moral and exemplary damages and attorneys’ fees; and (B) the CA gravely abused...(Subscriber-Only)
Issues:
- Was MERALCO entitled to recover the claimed unregistered consumption (the P232,385.20 differential billing) from Victoria?
- Did the Court of Appeals gravely abuse its discretion in awarding moral damages, exemplary damages, and attorneys’ f...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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