Case Digest (G.R. No. 90500)
Facts:
In Spouses Antonio and Lorna Quisumbing v. Manila Electric Company (Meralco) (429 Phil. 727, April 3, 2002), petitioners owned a Quezon City residence where, on March 3, 1995, Meralco inspectors led by Emmanuel Orlino conducted a routine meter check. The terminal and cover seals were found missing or deformed, the dials misaligned and the base plate scratched. Only Meralco personnel and the Quisumbings’ secretary witnessed the inspection. The meter was taken to Meralco’s laboratory, which confirmed tampering, and Meralco threatened immediate disconnection and demanded payment of PhP 178,875.01 as differential billing. Although service was restored the same afternoon, the spouses filed suit on March 6, 1995, alleging malicious disconnection without due process and seeking damages. The Regional Trial Court (RTC) ruled in their favor, awarding actual, moral and exemplary damages plus attorney’s fees. The Court of Appeals (CA) reversed, dismissed their complaint, and granted MeralcoCase Digest (G.R. No. 90500)
Facts:
- Parties and Background
- Spouses Antonio and Lorna Quisumbing purchased a house and lot at No. 94 Greenmeadows Avenue, Quezon City on April 7, 1994 and assumed liability for its electric service.
- Manila Electric Company (Meralco) is the authorized electric utility regulated by the Energy Regulatory Board (ERB).
- Inspection, Disconnection, and Proceedings
- On March 3, 1995, Meralco inspectors led by Emmanuel C. Orlino conducted a routine meter inspection at the Quisumbings’ residence, witnessed only by Meralco personnel and the plaintiffs’ secretary.
- Inspectors found missing seals, misaligned dials, and scratches indicative of meter tampering; they immediately disconnected service and demanded payment of P178,875.01 pending resolution. Service was later reconnected the same afternoon.
- On March 6, 1995, the Quisumbings filed suit for damages and a preliminary mandatory injunction alleging summary disconnection without due process. Meralco counterclaimed for a differential billing of P193,332.96.
- The Regional Trial Court (RTC) ruled in favor of the Quisumbings, finding a quasi-delict and awarding actual, moral, and exemplary damages plus attorney’s fees.
- The Court of Appeals (CA) reversed, dismissing the complaint and awarding Meralco its claimed billing differential.
Issues:
- Compliance with Statutory and Contractual Requirements
- Whether Meralco validly effected immediate disconnection under Section 4(a)(viii) of RA 7832 without an officer of the law or ERB representative personally witnessing and attesting to the discovery.
- Whether Meralco’s contractual “Terms and Conditions of Service” or BOE/ERB orders justify summary disconnection without complying with statutory or regulatory notice requirements.
- Entitlement to Damages
- Whether the Quisumbings proved actual damages with the requisite degree of certainty.
- Whether the summary disconnection without due process entitles the Quisumbings to moral and exemplary damages and attorney’s fees.
- Liability for Billing Differential
- Whether the Quisumbings are liable to pay the unregistered consumption differential of P193,332.96 based on uncontroverted documentary and testimonial evidence.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)