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.

Case Digest (G.R. No. 158911)

Facts:

Manila Electric Company v. Matilde Macabagdal Ramoy, G.R. No. 158911, March 04, 2008, the Supreme Court Third Division, Austria‑Martinez, J., writing for the Court.

Petitioner Manila Electric Company (MERALCO) sought review of the Court of Appeals (CA) Decision dated December 16, 2002, which ordered MERALCO to pay moral and exemplary damages and attorney’s fees to respondents, and the CA Resolution of July 1, 2003 denying MERALCO’s motion for reconsideration. The underlying controversy arose from MERALCO’s disconnection of electric service to respondents who occupied improvements near a National Power Corporation (NPC) right‑of‑way in Baesa, Quezon City.

Chronologically, NPC filed an ejectment case with the Metropolitan Trial Court (MTC) of Quezon City against several occupants of its property; the MTC rendered judgment on April 28, 1989 identifying the spatial location of structures occupied by Leoncio Ramoy. On June 20, 1990 NPC requested MERALCO to disconnect electric service to establishments beneath NPC transmission lines and furnished a list that included the Ramoy parties; MERALCO issued notices and subsequently disconnected the electric supply to the listed premises. MERALCO later requested and conducted a joint survey with NPC personnel to determine the meters to be disconnected.

Respondent Leoncio Ramoy (an original plaintiff who later died and was substituted in the CA) testified he owned the lot in question and that his residence was outside NPC property; during the disconnection he claimed he pointed out the boundary monuments but was threatened by armed men accompanying MERALCO employees. An ocular inspection ordered by the RTC likewise found the Ramoy residence outside the NPC right‑of‑way. The record also showed that MERALCO reconnected four other customers at NPC’s request, none of whom were the Ramoys.

The Regional Trial Court (RTC), Branch 81, Quezon City, dismissed respondents’ claims for moral and exemplary damages and attorney’s fees but ordered MERALCO to restore the electric supply. On appeal, the Court of Appeals r...(Subscriber-Only)

Issues:

  • Did the Court of Appeals err in finding MERALCO negligent in disconnecting the respondents’ electric service?
  • Was the Court of Appeals correct in awarding moral and exemplary damages and attorney’s fees against MERALCO under the...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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