Case Digest (G.R. No. 162894) Core Legal Reasoning Model
Facts:
The case involves Manila Electric Company (Meralco), represented by Vicente Montero, Mr. Bondoc, and Mr. Bayona as petitioners, and Nordec Philippines, represented by Dr. Potenciano R. Malvar, as respondent. Meralco was contracted to supply electricity to Marvex Industrial Corporation (Marvex) under a contract dated January 18, 1985, with metering devices installed on the same date. Marvex was billed based on monthly recorded consumption. On May 29 and September 18, 1985, Meralco's inspectors found that the meters at Marvex’s premises had been tampered with. Meralco consequently assessed differential billings totaling ₱496,386.29 and issued demand letters. When Marvex failed to pay, Meralco disconnected their electric service. Nordec acquired Marvex on August 16, 1988, but alleged that prior inspections were conducted without its consent, and that the disconnection happened without proper notice while a recomputation request was pending. Nordec filed a suit against Meralco
Case Digest (G.R. No. 162894) Expanded Legal Reasoning Model
Facts:
- Parties and Contractual Relationship
- Manila Electric Company (Meralco) contracted to supply electricity to Marvex Industrial Corporation (Marvex) under an Agreement for Sale of Electric Energy, with Service Account No. 9396-3422-15. Meralco installed metering devices at Marvex’s premises on January 18, 1985.
- Marvex was billed based on the monthly electric consumption recorded in its meter.
- Inspection and Allegations of Tampering
- On May 29, 1985, Meralco service inspectors inspected Marvex’s electric metering facilities and found tampering with the main meter terminal and cover seals. A second inspection on September 18, 1985, also revealed tampering.
- Meralco assessed differential billing of P371,919.58 for January 18, 1985 to May 29, 1985, and P124,466.71 for June 17, 1985 to September 18, 1985, totaling P496,386.29. Demand letters were sent (August 7 and November 29, 1985), and Meralco disconnected Marvex’s electric service upon non-payment.
- Change in Ownership and Litigation
- Nordec Philippines (Nordec), new owner of Marvex as of August 16, 1988, filed suit against Meralco for damages and preliminary injunction on December 23, 1986. Defendants included Meralco and certain employees.
- Nordec alleged unauthorized inspections by Meralco, a Power Field Order without defect mention, and pending recomputation request denied by Meralco. Meralco disconnected service without prior notice on December 18, 1986, causing loss of income and business opportunities.
- Trial Court Findings and Ruling
- The Regional Trial Court (RTC), Branch 85, Quezon City, found in its June 15, 2005 Decision that the meter had been tampered with, inspections were conducted with Nordec’s consent, and Meralco was justified in disconnecting service.
- The RTC dismissed Nordec’s complaints, found no contractual relationship between Nordec and Meralco, and ordered Nordec to pay Meralco P496,386.29 plus damages and attorney’s fees.
- Court of Appeals (CA) Decision
- The CA reversed the RTC's ruling in its January 21, 2011 Decision, ruling that Nordec had a contractual relationship with Meralco as the successor-in-interest to Marvex.
- CA held Meralco negligent in discovering the tampering after four months despite monthly meter readings and found that the new meter was defective. Meralco's failure to give 48-hour written notice of disconnection was also noted.
- CA awarded Nordec P5,625.00 for overbilling, P200,000.00 as exemplary damages, P100,000.00 attorney’s fees, and costs of suit.
- Motions for reconsideration by both parties were denied by the CA in a March 9, 2011 Resolution.
- Supreme Court Proceedings
- Meralco and Nordec filed separate Petitions for Review on Certiorari (G.R. Nos. 196020 and 196116) contesting the CA Decision and Resolution.
- Issues raised involved interpretation of evidence, contractual relationships, negligence in discovery of meter tampering, adequacy of notice for disconnection, and entitlement to damages and attorney’s fees.
Issues:
- Whether the Court of Appeals erred in making factual findings contrary to those of the Regional Trial Court.
- Whether Nordec Philippines had a cause of action against Manila Electric Company despite the original contract with Marvex.
- Whether Meralco was negligent in disconnecting Nordec’s electric supply and in discovering the tampered meters.
- Whether Nordec was entitled to damages (actual, temperate, moral, exemplary), attorney’s fees, and legal interest.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)