Case Digest (G.R. No. 195145)
Facts:
Manila Electric Company v. Spouses Sulpicio and Patricia Ramos, G.R. No. 195145, February 10, 2016, Second Division, Brion, J., writing for the Court.
Manila Electric Company (MERALCO) is the petitioner; Spouses Sulpicio and Patricia Ramos are the respondents. MERALCO supplied electricity to the respondents’ residence under a contract of service and installed meter no. 330ZN43953 on the front wall of premises occupied by Isidoro and Nieves Sales, adjacent to the respondents’ unit.
On November 5, 1999, a MERALCO service inspector inspected the respondents’ metering and found an outside connection attached to the respondents’ meter that the inspector traced to Nieves; Nieves signed the Metering Facilities Inspection Report. MERALCO disconnected the respondents’ electric service the same day while the respondents were absent from home. MERALCO later demanded payment of differential billing in the amount of P179,231.70.
On December 20, 1999, the respondents filed a complaint for breach of contract with preliminary mandatory injunction and damages before the Regional Trial Court (RTC), Branch 40, City of Manila, seeking immediate reconnection and actual, moral, exemplary damages, attorney’s fees and litigation expenses. In an August 22, 2006 decision, the RTC ordered MERALCO to reconnect the respondents’ service and awarded P2,000,000.00 in total damages (breakdown in the RTC decision).
MERALCO appealed to the Court of Appeals (CA). In its July 30, 2010 decision in CA‑G.R. CV No. 87843, the CA denied the appeal, affirmed the RTC’s reconnection order and damages award, and held that MERALCO failed to comply with the requirements of Sections 4 and 6 of Republic Act No. 7832 (R.A. 7832) before effecting immediate disconnection; it also found the respondents not liable for differential billing. MERALCO’s motion for reconsideration was denied by CA resol...(Pro-only)
Issues:
- Did MERALCO have the legal authority under procedural and statutory due process (R.A. 7832) to immediately disconnect the respondents’ electric service upon the inspection on November 5, 1999?
- Were the respondents liable for the differential billing MERALCO demanded?
- Were the awards of actual, moral, exemplary damages and attorney’s fees appro...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)