Case Summary (G.R. No. 84458)
Relevant Facts and Procedural History
Following the inspection, Inoferio prepared a Service Inspection Report indicating that the meter had a defect due to burned-out insulation. He recommended an adjustment to Victoria's billing, leading to a differential adjustment billing issued on October 3, 1995, amounting to P232,385.20. The notice stated that her metering defects had resulted in only 50% of her actual consumption being registered. In response, Victoria contested the findings, arguing the defect was a fortuitous event and that MERALCO had been negligent in not detecting the issue sooner. MERALCO's refusal to reconsider the billing led Victoria to file a complaint for injunction and damages with the Regional Trial Court (RTC) in Quezon City.
RTC Decision and Appeal
After a hearing, the RTC issued a Temporary Restraining Order and later a decision on June 1, 1999, prohibiting MERALCO from collecting the differential amount and requiring it to pay Victoria moral, exemplary damages, and attorney's fees. MERALCO subsequently appealed the decision to the Court of Appeals, which affirmed the RTC's ruling on March 26, 2002. MERALCO then filed a Petition for Review on Certiorari, asserting that the lower courts committed grave abuse of discretion in awarding damages and ruling on the differential billing.
Legal Principles for Injunction
In considering the issue of whether an injunction should have been issued in favor of Victoria, the Court reiterated the standard requirements: the existence of a clear and unmistakable right, a material and substantial invasion of that right, and an urgent necessity for the writ to prevent serious damage. MERALCO contended that Victoria had lost her right to uninterrupted service due to her refusal to pay the differential billing, which was deemed a violation of her service contract. Victoria, conversely, maintained her position that she had consistently paid her bills and contested the legitimacy of the differential billing.
Analysis of Contractual Obligations
The Court examined the service contract stipulation hold that in cases of a defective meter, the customer should be billed based on estimated consumption. It recognized the validity of such contractual provisions designed for the protection of service providers in instances of meter failure. However, it held that MERALCO must substantiate its claim for differential billing by proving: (a) that the meter was defective, (b) that it subsequently failed to register true consumption, and (c) that MERALCO was not negligent in its maintenance duties.
Findings on Meter Defectiveness
The appellate court concurred with the RTC that MERALCO had failed to substantiate the need for the differential billing against Victoria. Evidence showed that there was no significant disparity between Victoria's KWH consumption before and during the allegedly defective period, thereby undermining MERALCO's claims. The Court also noted the absence of dramatic fluctuations in her billing history, arguing that such a consistency contradicted the assertion that her consumption was significantly under-registered.
Evidence and Negligence Determination
Despite the existence of the Service Inspection Report supporting the claim of a defective meter, the Court distinguished this from demonstrating the extent of the meter's incapacity. It pointed out that MERALCO's claim hinged on internal company policy rather than empirical evidence of the meter's performance over the entire period in question, which contributed to its failure to establish its case against Victoria.
Liability for Differential Billing
MERALCO's negligence in timely inspecting and maintaining the electric meter was highlighted, establishing its liability. The
...continue readingCase Syllabus (G.R. No. 84458)
Overview of the Case
- The case involves a Petition for Review on Certiorari filed by the Manila Electric Company (MERALCO), seeking to annul the March 26, 2002 Decision of the Court of Appeals (CA), which affirmed the June 1, 1999 Decision of the Regional Trial Court (RTC).
- The respondent, Ma. Victoria D. Jose (Victoria), has been a customer of MERALCO since 1987, with an account that faced issues related to billing due to a defective electric meter.
Background Facts
- On July 14, 1995, MERALCO Inspector Santiago Inoferio inspected Victoria's electric meter and found defects that caused it to under-register consumption by 50%.
- Following the inspection, Victoria received a differential billing of P232,385.20, which MERALCO claimed was due to unbilled consumption resulting from the meter defect.
- Victoria contested the differential billing, asserting it was a result of negligence on MERALCO's part and that the defect should have been detected earlier.
Procedural History
- Victoria filed a Complaint for Injunction with Damages and a Writ of Preliminary Injunction against MERALCO in the RTC after receiving an overdue account notice threatening disconnection of her service.
- The RTC issued a Temporary Restraining Order and a Writ