Case Digest (G.R. No. L-18390) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Pedro J. Velasco vs. Manila Electric Co. et al., G.R. No. L-18390 (Decided August 6, 1971), plaintiff-appellant Dr. Pedro J. Velasco purchased three adjoining lots at the corner of South D and South 6 Streets, Diliman, Quezon City, in 1948 and built his residence on the third lot. He sold the two corner lots to Manila Electric Company (Meralco) but retained the lot adjacent to his home. In September 1953 Meralco constructed a 10,000 to 12,500 Kva substation without securing a building permit or Public Service Commission authority; it began operation in November 1953. From 1954 onward a continuous humming noise emanated 10 to 20 meters from Velasco’s home, allegedly disturbing his sleep, endangering his health and impairing the value of his property. Velasco sued for abatement of nuisance under Article 694 of the Civil Code and for damages under Article 2202, but the Court of First Instance of Rizal, Quezon City Branch, Civil Case No. 1355, dismissed his complaint, holding the Case Digest (G.R. No. L-18390) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Property Acquisition and Zoning
- In 1948, Pedro J. Velasco purchased three adjoining lots at the corner of South D and South 6 Streets, Diliman, Quezon City, in a district zoned “first residence.”
- Velasco sold two lots to Manila Electric Company (Meralco) and retained the third, upon which he built his residence approximately 10–20 meters from the future substation site.
- Substation Construction and Features
- Between September and November 1953, Meralco erected a high-voltage reducing substation without prior building permit or PSC authority.
- The facility comprised two transformers—either 5,000 kVA each (total 10,000 kVA) or 6,250 kVA each with fan cooling (total 12,500 kVA).
- Physical barriers included stone-and-cement walls along public streets and a wire-link fence along Velasco’s property line.
- Noise Emission and Health Claims
- A continuous humming/rumbling noise emanated day and night, audible within the house and up to 70 m away.
- Velasco alleged disturbance of sleep, impaired concentration, anxiety neurosis, pyelonephritis, ureteritis, lumbago, and anemia due to the noise.
- He sought abatement under Article 694, Civil Code, and damages under Article 2202, Civil Code, totaling P487,600.
- Trial Court Proceedings
- The Court of First Instance of Rizal dismissed the complaint, ruling the noise unavoidable, non-nuisance, and unproven as health causation; damage claims were inadequately supported.
- Velasco directly appealed to the Supreme Court.
Issues:
- Whether the continuous noise from Meralco’s substation constitutes an actionable nuisance under Article 694 of the Civil Code.
- Whether Velasco is entitled to injunctive relief or mandatory noise-reduction measures and to damages for health impairment and property devaluation.
- Whether Anastacio A. Agan, City Engineer of Quezon City, is solidarily liable for failing to require or enforce building permits and prosecute the nuisance.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)