G.R. No. 32931 - People vs. Makaraig y Buenaseda

Respondent Aguida Vda. de Santiago, the widow of late Jose Santiago, was a registered customer of petitioner Manila Electric Company (Meralco).
Since the death of her husband in October 1990, Aguida, along with her daughter, grandchildren, and a housemaid, resided at No. 26, Purok I Meyto, Calumpit, Bulacan under the same contract of service initially established by her late husband.

On March 10, 2000, Meralco’s inspector Antonio Cruz, accompanied by two other inspectors, conducted a routine inspection of Aguida’s meter installation situated outside her residence.
During the inspection, Cruz observed that a self-grounding wire was connected to the electric meter allegedly to deflect the actual consumption of electricity.
Based on his findings, Cruz disconnected the electric service, prepared a Meter/Socket Inspection Report and a Notice of Disconnection, and had Aguida sign the document.
Immediately thereafter, he demanded a payment for differential billing amounting to P65,819.75.

On the same day of the inspection, Aguida filed a protest with Meralco’s Malolos branch and its main office in Ortigas, Pasig City, contending that the inspection was conducted without her prior knowledge or permission and that it lacked the presence of a uniformed policeman or the participation of her neighbors as witnesses.
Despite her protest, Meralco forwarded a differential billing amounting to P385,467.10, citing the provisions of the contract of service and Republic Act No. 7832 (the “Anti-Electricity and Electric Transmission Lines/Materials Pilferage Act of 1994”) as justification for the immediate disconnection.

On April 4, 2000, Aguida filed a complaint for damages against Meralco before the Regional Trial Court (RTC) of Malolos, Branch 18.
In a Decision dated November 18, 2002, the RTC dismissed Aguida’s complaint for damages and ordered her to pay the differential billing of P65,819.75.
The RTC’s decision provided for immediate restoration of service upon payment of the alleged differential billing.

Both parties appealed the RTC decision. Meralco contested the amount to be paid, while Aguida challenged the procedural regularity of the inspection and disconnection.
On April 22, 2005, the Court of Appeals reversed the RTC’s ruling:

It found that Aguida’s electric service had been disconnected without due process of law.
It ordered Meralco to pay Aguida moral damages (P100,000.00), exemplary damages (P50,000.00), and attorney’s fees (P20,000.00).
It dismissed Meralco’s claim for differential billing and directed the immediate restoration of Aguida’s electric service.

Meralco raised several issues in its petition for review on certiorari, questioning the sufficiency of evidence on meter tampering, the observance of due process, and the propriety of awarding damages.
Among others, it argued that:

A key point of contention was the testimony of PO2 Chavez, a police officer who allegedly witnessed the inspection.
Discrepancies were noted as Chavez, assigned in Caloocan City, was not from Bulacan, and he failed to present a written order authorizing his presence in Calumpit.
Additional evidence, such as billing records from May 1999 to February 2000, revealed no drastic changes in consumption that could support a claim of meter tampering, except for an isolated billing anomaly later attributed to a defective meter rather than tampering.

Whether the Court of Appeals erred in ruling that there was no solid, strong, and satisfactory evidence to prove that Aguida engaged in meter tampering.
Whether the court correctly determined that Meralco did not observe due process of law when it disconnected Aguida’s electric service.
Whether the Court of Appeals was justified in disregarding Meralco’s contractual right to disconnect the service pursuant to the provisions of Republic Act No. 7832.
Whether the Court of Appeals erred in reversing the RTC’s decision by awarding damages to Aguida rather than upholding the dismissal of her complaint for damages.