Case Digest (G.R. No. 170482)
Facts:
Manila Electric Company v. Aguida Vda. de Santiago, G.R. No. 170482, September 04, 2009, Supreme Court Second Division, Quisumbing, J., writing for the Court.Petitioner Manila Electric Company (Meralco) sought review of the Court of Appeals’ Decision dated April 22, 2005 and Resolution dated November 21, 2005 in CA-G.R. CV No. 78800, which had reversed the Regional Trial Court (RTC) of Malolos, Branch 18. Respondent Aguida Vda. de Santiago (Aguida) sued Meralco for damages after Meralco disconnected the electric service at the residence registered to her late husband.
The underlying facts are that Aguida had been the user under the service contract of her late husband’s account. On March 10, 2000, Antonio Cruz, a Meralco inspector, with two other inspectors conducted an inspection of the meter installation at Aguida’s house and allegedly found a self-grounding (shunting) wire. Cruz disconnected the service, prepared a Meter/Socket Inspection Report and a Notice of Disconnection which Aguida signed, and demanded payment of a "differential billing" of P65,819.75. Aguida filed an internal protest with Meralco claiming she was not notified and denying the presence of a policeman in uniform during the inspection. Meralco later issued a differential bill of P385,467.10 and invoked the provisions of Republic Act No. 7832 (Anti-Electricity Pilferage Act) to justify immediate disconnection.
Aguida filed a complaint for damages before the RTC of Malolos on April 4, 2000. In a Decision dated November 18, 2002, the RTC dismissed Aguida’s complaint and ordered her to pay Meralco P65,819.75 as differential billing, directing Meralco to restore service upon payment. Both parties appealed to the Court of Appeals: Meralco disputed the amount and legality of the CA’s later disposition; Aguida contested the RTC’s finding of a regular inspection.
The Court of Appeals, in a Decision dated April 22, 2005, set aside and reversed the RTC, finding that Aguida had been deprived of electricity without due process and that there was insufficient evidence of tampering; it dismissed Meralco’s P385,467.10 claim, ordered Meralco to pay...(Pro-only)
Issues:
- Whether there was sufficient proof that respondent was using a self-ground wire (meter tampering).
- Whether Meralco observed due process of law when it discontinued respondent’s electric service.
- Whether Meralco could lawfully disconnect respondent’s electric service pursuant to the provisions of R.A. No. 7832.
- Whether the Court of Appeals erred in awardin...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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