Case Digest (G.R. No. 109389)
Facts:
Manila Electric Company v. Spouses Hua Kim Peng and Angelita Ramoran, G.R. No. 109389, June 26, 2006, Supreme Court Second Division, Sandoval‑Gutierrez, J., writing for the Court.On December 7, 1988, Spouses Hua Kim Peng and Angelita Ramoran (respondents) filed a Complaint for Injunction with Damages against Manila Electric Company (MERALCO) (petitioner) in the Regional Trial Court (RTC), Branch 81, Quezon City (Civil Case No. Q‑88‑1323). The complaint alleged that respondents owned two small plastic factories and three residential units at 153 West Riverside, Quezon City, served by five separate MERALCO meter accounts. The meters were originally inside respondents’ compound but had been transferred by MERALCO to the outside wall, leaving one idle meter base inside.
Respondents claimed that on September 24, 1988 MERALCO’s inspection team entered the compound, removed the idle meter base and presented pink papers to Leticia Zamora (respondent Angelita’s cousin) alleging that “jumpers” were connected so meters would not register actual consumption. Respondents’ counsel asked for another inspection (registered letter dated September 28, 1988), but MERALCO did not comply; instead, MERALCO later sent five “CONFIDENTIAL” demand letters totaling P1,811,933.08 for alleged “used but unregistered electricity” and threatened disconnection. Respondents sought injunctive relief and damages.
MERALCO answered, denied the material allegations, alleged its crew found permanent jumpers, produced photographs and laboratory confirmation, and counterclaimed for P1,811,933.08, asserting its charter and service contracts authorized discontinuance for nonpayment. The RTC issued a temporary restraining order and a writ of preliminary injunction enjoining MERALCO from disconnecting service, but after trial rendered judgment on April 8, 1991 dismissing the complaint and, on MERALCO’s counterclaim, ordered respondents to pay P1,811,933.08 with interest and costs.
Respondents appealed to the Court of Appeals (CA, CA‑G.R. CV No. 32460). By Decision dated March 19, 1993, the CA reversed and set aside the RTC, permanently enjoined MERALCO from cutting the plaintiffs’ electrical connections on the grounds raised, awarded P50,000 moral and P50,000 exemplary damages, P50,000 attorney’s fees, and costs, and dismissed other claims/counterclaims. The CA relied on photographic evidence and billing history to conclude the alleged jumpers did not prevent meter registration and that MERALCO’s differential billing lacked rational basis....(Subscriber-Only)
Issues:
- In a Rule 45 petition for review on certiorari, may the Supreme Court reexamine factual findings of the Court of Appeals when the appellate and trial courts’ findings conflict?
- Did MERALCO prove the existence of illegal jumpers and the rational basis of its differential billing and corresponding right to recover P1,811,933.08 and to disco...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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