Case Summary (G.R. No. 45450)
Applicable Law
The case is governed primarily by the provisions of the 1987 Philippine Constitution and relevant legislation, particularly Republic Act No. 7638, which created the Department of Energy (DOE) and transferred specific regulatory responsibilities from the ERB to the DOE regarding energy resources.
Factual Background
The factual background reveals that the members of AMI, registered enterprises operating within the franchise area of ILPI, were granted direct power supply connections by NPC. In response, ILPI filed a petition with the ERB to discontinue this direct supply, arguing that it was essential for maintaining its franchise rights. The ERB initially attempted to assert jurisdiction over the matter despite AMI's contention that the DOE was the appropriate agency following the legislative changes outlined in Republic Act No. 7638.
Court of Appeals’ Findings
The Court of Appeals ultimately ruled in favor of AMI, determining that the DOE held jurisdiction over the issues of direct power supply connections. The appellate court characterized ILPI's petition as one primarily concerning energy distribution rather than rate fixing, thereby aligning it with the DOE's responsibilities as transferred under Republic Act No. 7638.
Jurisdiction Issue
The primary legal issue is whether the ERB retains jurisdiction to decide matters concerning direct connections of electricity supply in light of the provisions of Republic Act No. 7638. The petitioners argued that the regulatory powers conferred upon the ERB by earlier legislation had not been fully transferred to the DOE. However, the court emphasized that the jurisdiction over energy distribution, including direct connections, is a non-price regulatory matter now under the DOE's auspice.
Contentions of Petitioners and Respondents
Petitioners asserted that the regulatory role of ERB retained authority regarding direct connections, particularly due to previous cabinet policies prior to the enactment of Republic Act No. 7638. Contrarily, respondents maintained that the jurisdiction over the matter belongs to the DOE, citing past jurisprudence that affirmed the DOE's authority in energy supply disputes.
Supreme Court's Ruling
The Supreme Court reaffirmed the Court of Appeals' ruling, stating that the jurisdiction over matters involving the distribution of energy resources, including decisions regarding direct connections of electricity, was prop
...continue readingCase Syllabus (G.R. No. 45450)
Case Overview
- Petitioners: Energy Regulatory Board (ERB) and Iligan Light & Power, Inc. (ILPI)
- Respondents: Court of Appeals and Association of Mindanao Industries (AMI), including member companies such as Alson/Iligan Cement Corp., Mabuhay Vinyl Corp., MCCI Corp., Mindanao Ferroalloy Corp., and National Steel Corp.
- Decision Date: March 25, 1999
- Case Citation: 364 Phil. 811
Factual Background
- The case revolves around the sale of electric power generated by the National Power Corporation (NPC) through authorized private utility firms within specific franchise areas.
- The private respondents, members of AMI, obtained power directly from NPC, bypassing the franchise holder, ILPI.
- ILPI petitioned the ERB to terminate this direct supply, citing the Cabinet Policy Reforms approved by the President on January 21, 1987.
- The Cabinet Policy stipulated that direct connections for industries authorized by the BOI-NPC Memorandum should continue until determined unnecessary by the relevant regulatory board.
- ILPI claimed it could meet the financial standards set by ERB to justify the discontinuation of direct supply.
Court of Appeals' Decision
- The Court of Appeals ruled in favor of AMI, asserting that jurisdiction over direct connection and disconnection