Case Summary (G.R. No. 171624)
Background of the Dispute
On June 23, 2003, BF Homes and PWCC filed a petition in the Regional Trial Court (RTC) against Meralco, invoking their right to a refund based on a prior Supreme Court ruling. The dispute centers on a mandated refund from Meralco to its customers following Supreme Court decisions that required Meralco to refund excess billing amounts starting from February 1998, amounting to PHP 11,834,570.91 owed to the petitioners.
Allegations Against Meralco
The petitioners claimed that Meralco disconnected electric supply to their water pumps on May 20, 2003, without prior notice, disrupting water delivery to their customers. They further alleged that Meralco's actions displayed bad faith, particularly in denying their requests to apply electric bills against the refund amount owed. Additionally, Meralco threatened further disconnections, asserting a right to demand payment for outstanding bills totaling PHP 4,717,768.15.
Petition for Injunctive Relief
The petitioners sought a writ of preliminary injunction to prevent Meralco from cutting off electricity to their water pumps, arguing that the disconnection would result in irreparable harm to their water supply services and lead to potential social unrest in the community. The RTC initially granted the injunction, recognizing the fundamental right to water access and the community's need for uninterrupted water service.
Meralco's Defense and Counterclaims
In its defense, Meralco argued that it is a public utility company entitled to discontinue service for non-payment of electric bills, as stipulated in their service agreements with the petitioners. Meralco maintained that the RTC lacked jurisdiction in the matter, citing that issues regarding rates and service disputes fall under the jurisdiction of the Energy Regulatory Commission (ERC). Meralco counterclaimed for outstanding payments and sought moral, exemplary damages, and attorney's fees.
RTC's Ruling
The RTC ruled in favor of BF Homes and PWCC, agreeing that the disconnection would cause irreparable injury and thus granted the injunction. Meralco's motion for reconsideration was denied, with the RTC reiterating its position on the necessity of the injunction to protect the community's right to water.
Court of Appeals Decision
Meralco subsequently filed a petition for certiorari with the Court of Appeals, which reversed the RTC's decision, ruling that the RTC did not have jurisdiction over the matter. The appellate court emphasized that the ERC held exclusive jurisdiction over rate disputes and service discontinuations. The court found that the issue required technical adjudication by the ERC, invoking the doctrine of primary jurisdiction.
Supreme Court Proceedings
BF Homes and PWCC appealed to the Supreme Court, arguing that the Court of Appeals erred in declaring that the RTC lacked jurisdiction. They asserted that their request for injunctive relief was a separate issue from the merits of the underlying case and should be addressed by the RTC.
Supreme Court's Final Ruling
The Supreme Court affirmed the decision of the Court of Appeals, citing the principle that jurisdiction lies
...continue readingCase Syllabus (G.R. No. 171624)
Case Background
- The case involves a Petition for Review on Certiorari filed by BF Homes, Inc. (BF Homes) and Philippine Waterworks and Construction Corporation (PWCC) against Manila Electric Company (MERALCO).
- The petition challenges the October 27, 2005 Decision of the Court of Appeals which nullified and set aside the November 21, 2003 Order of the Regional Trial Court (RTC) of Las Piñas City. This Order had previously granted a writ of preliminary injunction preventing MERALCO from disconnecting electric power to BF Homes and PWCC’s water pumps.
- The RTC's decision was also contested in a subsequent Motion for Reconsideration, which was denied by the Court of Appeals.
Parties Involved
- Petitioners: BF Homes, Inc. and Philippine Waterworks and Construction Corporation.
- These entities operate waterworks systems serving over 12,000 households and commercial establishments across several cities including Parañaque, Las Piñas, Caloocan, and Quezon City.
- Respondent: Manila Electric Company (MERALCO).
- A corporation engaged in the distribution and sale of electric power in Metro Manila.
Facts of the Case
- On June 23, 2003, BF Homes and PWCC filed a petition with the RTC, seeking a preliminary injunction against MERALCO, citing a right to a refund based on the Supreme Court's ruling in the MERALCO Refund cases.
- The Supreme Court had mandated MERALCO to refund an excess average charge of P0.167 per kilowatt hour starting February 1998.
- BF Homes and PWCC claimed that MERALCO disconnected their electric supply without notice on May 20, 2003, which disrupted their water service.
- They alleged that MERALCO demand