Case Summary (G.R. No. 128066)
Applicable Law
This case operates under the 1987 Philippine Constitution, with particular reference to Republic Act No. 7832, which addresses the illegal use of electricity and mandates specific procedures for the disconnection of electricity due to meter tampering.
Factual Background
The dispute began with Meralco's inspection of the respondents' electric meter on April 19, 1994, which they alleged was tampered with. Following this accusation, Meralco disconnected the electricity supply without prior written notice, citing losses from the alleged tampering.
Procedural History
The respondents filed a petition with the Regional Trial Court (RTC) of Pasig City seeking an injunction against the disconnection, reimbursement for overpaid electric bills, and the reinstatement of their original meter. The RTC granted a preliminary injunction against Meralco and ultimately ruled in favor of the respondents, ordering Meralco to pay damages.
Trial Court Decision
On July 9, 2003, the RTC found that Meralco had violated due process by disconnecting the electric service without proper legal procedure. The court highlighted that, per RA 7832, the presence of a legitimate officer from the Energy Regulatory Board (ERB) during the discovery of the tampered meter was necessary for prima facie evidence of illegal use. Consequently, the RTC awarded the respondents substantial damages for the overpayments and mental anguish caused by the wrongful disconnection.
Court of Appeals Ruling
On May 21, 2008, the Court of Appeals modified the RTC's ruling, deleting the reimbursement for the overpayments but granting the respondents temperate damages of P500,000. The appellate court affirmed that Meralco had abused its right to disconnect the electricity service without providing the required notice, as mandated by Section 97 of the Revised Order No. 1 under the Public Service Commission regulations.
Petitioner’s Arguments
Meralco contested the awards of moral and exemplary damages, arguing that the disconnection for one day did not significantly affect the respondents’ operations, as they utilized generators immediately following the disconnection. Moreover, Meralco asserted that its personnel were justified in their actions based on the evidence of meter tampering.
Respondents’ Counterarguments
The respondents maintained that they were not involved in tampering with the meter and emphasized that the utility company’s actions lacked due process. They highlighted the significant increase in electric bills following the installation of a new meter as evidence of overbilling, asserting their claim for actual damages.
Legal Analysis
The Supreme Court highlighted the importance of due process in electric service disconnection, reinforcing the requirement for prior written notice to customers even in cases of suspected fraud. The Court also pointed out that the absence of an ERB representative during the discovery of the alleged tampering invalid
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Case Overview
- The case involves a petition for review on certiorari filed by Manila Electric Company (Meralco) against Atty. Pablito M. Castillo and Guia S. Castillo.
- The petition seeks to overturn the Decision dated May 21, 2008, of the Court of Appeals, which modified the Regional Trial Court’s (RTC) ruling in favor of the respondents.
- The RTC's original Decision dated July 9, 2003, awarded significant damages to the respondents for overpaid electricity bills and for the wrongful disconnection of their electric service.
Background of the Case
- Respondents, Pablito M. Castillo and Guia S. Castillo, are spouses operating a business named Permanent Light Manufacturing Enterprises, manufacturing fluorescent fixtures and office cabinets.
- On March 2, 1994, Permanent Light was awarded a contract by the Government Service Insurance System (GSIS) for 1,200 steel filing cabinets worth P7,636,800.
- On April 19, 1994, Meralco inspectors discovered that Permanent Light's electric meter had been tampered with, leading to an immediate disconnection of service.
Findings of Meter Tampering
- The inspection revealed deformation of the terminal seal, fake seals, and misalignment of the meter's dial pointer.
- Following the inspection, Meralco claimed losses amounting to P126,319.92 over 24 months due to the alleged tampering.
- Respondents paid an initial P50,000 as a down payment towards a differential bill.
Billing Disputes
- Meralco issued a bill of P61,709.11 for unregistered consumption, which was later reduced