Case Digest (G.R. No. 125687)
Facts:
Manila Electric Company v. T.E.A.M. Electronics Corporation, G.R. No. 131723, December 13, 2007, Supreme Court Third Division, Nachura, J., writing for the Court.Petitioner Manila Electric Company (Meralco) is a utility supplying electricity in Metro Manila. Respondent T.E.A.M. Electronics Corporation (TEC) (formerly NS Electronics and National Semi-Conductors) is wholly owned by respondent Technology Electronics Assembly and Management Pacific Corporation (TPC). Ultra Electronics Instruments, Inc. (Ultra) leased TEC’s Dyna Craft International Manila (DCIM) building from 1986 until its ejectment in February 1988.
Meralco and TEC’s predecessor entered several Agreements for the Sale of Electric Energy covering meters at the DCIM and TEC’s NS Building. On September 28, 1987 Meralco inspectors conducted a surprise inspection of two DCIM meters and prepared Service Inspection Reports, alleging meter tampering and computing an unregistered-consumption differential of P7,040,401.01 (covering February 10, 1986 to September 28, 1987). Meralco informed TEC by letter (November 25, 1987); TEC referred the demand to Ultra, which questioned the assessment as excessive. Meralco disconnected power to the DCIM building on April 29, 1988 for nonpayment. TEC filed an ERB complaint (later withdrawn), and after paying P1,000,000.00 under protest, service was reconnected only on October 12, 1988; Meralco had inspected again on June 7, 1988 and alleged fresh tampering.
Separately, Meralco inspected TEC’s NS Building on April 25, 1988 and billed a differential of P280,813.72 by letter dated June 18, 1988; TEC denied the claim and later paid the amount under protest to avoid disconnection.
TEC and TPC sued Meralco and Ultra before the Regional Trial Court (RTC), Pasig, docketed Civil Case No. 56851 (filed January 13, 1989). At pre-trial the issues were limited to (a) Meralco’s liability for disconnection at DCIM; (b) whether TEC was liable to Meralco for differential billings of P7,040,401.01; and (c) entitlement to exemplary damages. After trial, on June 17, 1992 the RTC rendered judgment for TEC and TPC against Meralco and Ultra, ordering reimbursement and awarding actual, exemplary and moral damages, and attorneys’ fees. The RTC found Meralco’s evidence insufficient to prove TEC’s tampering, criticized Meralco’s delay in notifying TEC, and held the disconnection an act of bad faith.
Meralco appealed to the Court of Appeals (CA). The CA, in a decision dated June 18, 1997, affirmed the RTC with modifications to damages and interest, finding Meralco negligent in inspection, belated notific...(Subscriber-Only)
Issues:
- Under the record, did TEC tamper with the electric meters installed at its DCIM and NS buildings?
- If tampering is established, is TEC liable for the differential billing as computed by Meralco (P7,040,401.01 and P280,813.72)?
- Was Meralco justified in disconnecting the electric power supply to TEC’s DCIM buildin...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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