Case Summary (G.R. No. 171534)
Factual Background
On January 17, 1991, Meralco's service inspectors conducted a routine inspection of the electric meters at the respondent’s premises, which was attended by the respondent’s president, Mr. William Belo. During the inspection, the inspectors discovered that the electric meter was allegedly tampered with, as it failed to register the correct amount of electricity consumed. The findings were documented in a Service Inspection Report, followed by the removal of the meter for laboratory analysis. The lab results indicated multiple signs of tampering, including missing seals and misaligned dials.
Subsequently, on February 20, 1991, Meralco informed Wilcon of the tampering and demanded payment of ₱250,565.59 for the alleged unregistered consumption. After the respondent failed to make the payment and a final demand was issued on December 6, 1991, Meralco initiated a legal suit claiming damages, seeking a court order for the payment of the differential billing with interest and attorney's fees.
Respondent's Position
In its defense, Wilcon denied any wrongdoing regarding the alleged tampering, asserting that its reduced electricity consumption was due to the breakdown of a 7.5 ton air-conditioning unit that had become non-functional by 1986. Moreover, it stated that Meralco had offered to settle the case for around ₱70,000 but the settlement was not accepted, leading to the initiation of litigation.
Pre-Trial and Trial Court Decision
During the pre-trial, the parties narrowed down the issues to whether the meter was tampered with and the resultant liability for the differential billing. The Regional Trial Court (RTC) ruled in favor of Meralco on June 29, 1998, ordering Wilcon to pay actual damages, attorney's fees, and costs of suit. The RTC found the evidence presented by Meralco credible, attributing the tampering to the respondent under the presumption that the tampered meter, located on its premises, implied wrongdoing by the respondent. However, the RTC also recognized the non-usage of the air-conditioning unit, which prompted a 25% discount on the total amount owed.
Court of Appeals Decision
The decision of the RTC was appealed to the Court of Appeals (CA), which reversed and set aside the lower court's ruling. The CA determined that the decrease in electricity consumption was primarily due to the breakdown of the air-conditioning unit, rather than any tampering of the meter. The appellate court found negligence on the part of Meralco for failing to inspect the meter for a significant period, thus allowing the purported tampering to go unnoticed from 1984 to 1991.
Issues Presented for Review
Meralco subsequently sought a review from the Supreme Court, raising several arguments, including claims of reversible error by the Court of Appeals in applying the Ridjo Tape doctrine, making its own factual findings, and in dismissing the civil case filed against the respondent.
Supreme Court Analysis
The Supreme Court rejected Meralco’s assertions, affirming the CA's application of the Ridjo Tape doctrine, which mandates public utilities to perform regular inspections of their meters and equipment. The doctrine stipulates that prolonged negligence in identifying defects or tampering allows consumers to minimiz
...continue readingCase Syllabus (G.R. No. 171534)
Case Overview
- The case is a review of the Decision of the Court of Appeals (CA) dated June 30, 2005, and its Resolution dated February 10, 2006, in CA-G.R. CV No. 60723, which reversed the ruling of the Regional Trial Court (RTC) in Civil Case No. 64678.
- The petitioner is the Manila Electric Company (Meralco), a utility company engaged in the distribution and sale of electric power.
- The respondent is Wilcon Builders Supply, Inc., a registered customer of Meralco under Account No. 05380-0800-19.
Factual Background
- On January 17, 1991, during a routine inspection witnessed by the respondent's president, Mr. William Belo, the electric meter at Wilcon's premises was allegedly found tampered with, leading to incorrect registration of consumed electricity.
- The inspection resulted in the preparation of a Service Inspection Report, Power Metering Field Order, and Meter Removal Form, after which the tampered meter was sent for laboratory examination.
- The laboratory test revealed several signs of tampering, including missing seals and misaligned dial pointers.
- Following the inspection, Meralco demanded payment from Wilcon for unregistered electricity consumption amounting to P250,565.59.
Judicial Proceedings
- Wilcon denied any wrongdoing, attributing increased consumption to