Case Digest (G.R. No. 176830) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Manila Electric Company (MERALCO) vs. Lucy Yu, G.R. No. 255038, decided on June 26, 2023 under the 1987 Constitution, MERALCO is a domestic public utility engaged in supplying electricity in Metro Manila. Respondent Lucy Yu, through her family-owned New Supersonic Industrial Corporation (NSIC), manufactures appliance parts at 8 Dr. Manuel St., Fortune Village, Phase 4, Paso de Blas, Valenzuela City. Yu held MERALCO Service Identification No. 801498301, which also covered her residence. On December 9, 1999, MERALCO representatives, led by Engineer William T. Chan and accompanied by plainclothes individuals and PNP officers, inspected Yu’s electric meter, allegedly discovered a reversing current transformer, and cut the electricity supply the same day after issuing a notice of disconnection. Yu’s business and residence remained powerless until 2008 despite a December 12, 2003 RTC order granting a writ of preliminary injunction. On January 24, 2000, Yu filed a complaint for dama... Case Digest (G.R. No. 176830) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioner Manila Electric Company (MERALCO) is a domestic public utility corporation supplying electricity in Metro Manila and nearby areas.
- Respondent Lucy Yu is a registered MERALCO customer under SIN 801498301 and owner of New Supersonic Industrial Corporation (NSIC), a manufacturing enterprise using the same service account.
- Agreement and Service Accounts
- MERALCO agreed to supply electricity to Yu’s residence and NSIC factory at 8 Dr. Manuel St., Valenzuela City.
- NSIC’s operations relied on continuous electric service for appliance spare parts production.
- Complaint and Injunction
- On December 9, 1999, MERALCO representatives, led by Engr. William T. Chan with PNP officers, inspected Yu’s meter and issued a same-day Notice of Disconnection.
- MERALCO disconnected power to Yu’s residence and NSIC factory without prior due notice, prompting Yu’s complaint for damages and injunction (January 24, 2000).
- The RTC granted a preliminary injunction on December 12, 2003, ordering restoration; full restoration occurred only in 2008.
- Trial Evidence
- Yu’s proof of actual damages: testimony of NSIC’s production manager and comparative production data claiming P23,500,000 loss.
- MERALCO’s defense: alleged meter tampering by a reversing current transformer, presence of PNP officers during inspection, confiscation of transformer (destroyed by fire), and computed differential billing of P33,936,707.15.
- Lower Courts’ Decisions
- RTC Decision (July 27, 2018): found MERALCO violated RA 7832 for lack of prior notice; awarded temperate (₱300,000), moral (₱100,000), exemplary (₱50,000) damages; dismissed counterclaim.
- CA Decision (November 26, 2020): affirmed RTC but increased exemplary damages to ₱500,000.
Issues:
- Whether MERALCO complied with disconnection requirements under RA 7832 (Section 4(a) and Section 6).
- Whether MERALCO is liable to Yu for temperate, moral, and exemplary damages.
- Whether MERALCO is entitled to its counterclaim for differential billings.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)