Case Digest (G.R. No. L-62038)
Case Digest (G.R. No. L-62038)
Facts:
National Electrification Administration (NEA) and Oriental Mindoro Electric Cooperative I (ORMECO), Petitioners, G.R. No. 62038. September 25, 1985. Supreme Court Second Division. Alampay, J., writing for the Court.On February 20, 1981, ORMECO I notified its consumers that, effective March 1, 1981, it would collect increased electric rates authorized by NEA on February 4, 1981. On March 17, 1981 the Integrated Bar of the Philippines (IBP), Oriental Mindoro Chapter filed in the Court of First Instance (CFI) of Oriental Mindoro Civil Case No. R-3326 seeking to enjoin the implementation of the rate increase; the presiding judge issued a restraining order the same day.
ORMECO I answered on March 26, 1981, contesting jurisdiction and seeking dissolution of the restraining order. The CFI temporarily dissolved the restraining order and dismissed the petition on April 10, 1981, but reinstated the restraining order after the IBP moved for reconsideration. On September 4, 1981, NEA moved to intervene (granted October 23, 1981) and then moved to dismiss for lack of jurisdiction, contending that rate approval for cooperatives fell within NEA’s exclusive competence. The CFI denied NEA’s motion to dismiss on December 17, 1981, holding it could enjoin the rate change because no public hearing had been conducted.
Upon motions by the IBP, the CFI issued orders dated March 3 and March 10, 1982 directing the Provincial Auditor to assist an examination of ORMECO I’s records and fixing a rate of P1.72/kWh. NEA noted that it had been a creditor of ORMECO I since a March 27, 1973 loan and that the cooperative’s rates were subject to approval by NEA’s Board of Administrators under a stipulation between the parties. The orders and the CFI’s refusal to dismiss the injunctive suit prompted NEA and ORMECO I to file a petition for certiorari before the Supreme Court seeking to set aside the CFI’s orders and to dismiss Civil Case No. R-3326 for lack of jurisdiction.
Issues:
- Did the Court of First Instance have jurisdiction to restrain the implementation of rates approved by NEA and to issue the challenged orders in Civil Case No. R-3326?
- Had the IBP exhausted available administrative remedies before resorting to the courts, or was it obliged to seek administrative review (including appeal to the President) of NEA’s action?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)