US vs. Carlos, 21 Phil.

543
FACTS:
Ignacio Carlos has been a consumer of electricity furnished by
MERALCO. Ignacio Carlos used a jumper and was thus able to
divert the flow of electricity, causing loss to the MERALCO of
over 2273 kilowatts of current. Accused of theft, his defense was
that electricity was an unknown force, not a fluid, and being
intangible, could not be the object of theft.
ISSUE:
Can electricity be the object of theft?
DECISION:
YES. Electricity can be the object of theft. Theft of incorporeal
objects, like electricity, is possible. While electric current is not a
fluid, still its manifestations and effects like those of gas may be
seen and felt. The true test of what may be stolen is not whether
it is corporeal or incorporeal, but whether it is capable of
appropriation by another. Electricity, like gas, is valuable
merchandise, and may thus be stolen.