Title
Manila Electric Co. vs. Macabagdal
Case
G.R. No. 158911
Decision Date
Mar 4, 2008
MERALCO disconnected power based on NPC's request without verifying property boundaries, leading to a breach of contract. SC upheld moral damages for Ramoy but denied exemplary damages and attorney's fees.
A

Case Digest (G.R. No. 140733)

Facts:

  • Ejectment Proceedings
    • In 1987, National Power Corporation (NPC) filed an ejectment case before the MTC Quezon City against alleged illegal occupants, including Leoncio Ramoy, on NPC’s right-of-way in Baesa, Quezon City.
    • On April 28, 1989, MTC Branch 36 rendered judgment in favor of NPC, ordering the demolition of structures and vacation of the premises; Leoncio Ramoy was specifically found to occupy Lot No. 72-B-2-B (Exhs. 2, 2-A to 2-C).
  • Disconnection of Electric Service
    • On June 20, 1990, NPC requested Meralco to disconnect electricity to all establishments under NPC transmission lines, attaching the MTC decision and list of affected establishments, including respondents.
    • Meralco issued disconnection notices (Exhs. 3 to 3-I) and, despite a joint NPC-Meralco survey, disconnected power to respondents’ premises; Leoncio Ramoy protested, showing boundary monuments, but was threatened by armed men accompanying Meralco personnel.
  • Trial and Intermediate Appeals
    • The RTC of Quezon City (Branch 81) dismissed respondents’ claims for moral and exemplary damages and attorney’s fees, but ordered Meralco to restore service (RTC Decision, Sept. 24, 1996).
    • The Court of Appeals (CA), in its December 16, 2002 Decision, held Meralco negligent for disconnecting without a writ of execution or coordinating with court officers, awarded moral and exemplary damages and attorney’s fees; its July 1, 2003 Resolution denied Meralco’s motion for reconsideration.
    • Meralco filed a petition for review on certiorari under Rule 45 before the Supreme Court.

Issues:

  • Whether Meralco was negligent in disconnecting respondents’ electric service.
  • Whether respondents are entitled to moral and exemplary damages and attorney’s fees.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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