MANILA ELECTRIC COMPANY

VS
MATILDE MACABAGDAL RAMOY, ET AL
G.R. NO. 158911, MARCH 4, 2008

CASE DOCTRINE:
In culpa contractual, the mere proof of the existence of the
contract and the failure of its compliance justify, prima facie, a
corresponding right of relief.

PERITINENT ARTICLE: New Civil Code, Article 1170

FACTS:
National Power Corporation (NPC) filed with MTC Quezon City
alleging that several persons were illegally occupying their property in
Baesa, Quezon City among of which are the respondents.
Respondents failed to submit their reply in spite of summons and
then the MTC rendered a judgement to order the defendants to
remove their buildings and structures on the NPC’s property and
vacate the premises.

NPC then ordered MERALCO to disconnect the electrical

power supply to all of the residential and commercial buildings
beneath the NPC transmission lines. MERALCO complied with the
NPC order which also included with the respondents.

Respondents testified that the disputed lot was registered as

their property which said lot was also occupied by the other
respondents. Despite pleading with the MERALCO staff who came to
cut off their power supply by pointing out that their property was
outside of the NPC premises, the armed MERALCO staff just shooed
them away and cut off their power supply anyway causing the
respondents to vacate the premises.

After ocular inspections ordered by the court, it has been

proven that the property of the respondent was indeed outside of the
disputed property of the NPC. This was also confirmed by one of the
MERALCO staff who did not disclose this information to his superiors.

RTC decided in favor of MERALCO by dismissing respondents’

claim for moral and exemplary damages but ordered MERALCO to
reconnect the power supply of the respondents. Respondents then
appealed to the CA where the CA decided that MERALCO is at fault
for not requiring NPC to show a writ of execution or demolition and
not coordinating with the proper authorities before complying with
NPC. Thus, CA held petitioner liable for moral and exemplary
damages. Aggrieved, petitioners filed with the SC a petition for
certiorari.
ISSUE: Whether or not MERALCO is liable for damages

RULING:
Yes. MERALCO is liable for damages. MERALCO admits that
they and respondents are under a Service Contract. The
respondents’ action against MERALCO is based on culpa contractual
for the unjust service interruption. This can be found under Article
1170 of the New Civil Code.

The Supreme Court agrees with the CA that under the factual
milieu of the present case, it was not enough for MERALCO to merely
rely on the Decision of the MTC without ascertaining whether it had
become final and executory. The utmost care and diligence required
of MERALCO necessitates such great degree of prudence on its part,
and failure to exercise the diligence required means that MERALCO
was at fault and negligent in the performance of its obligation.
Therefore, MERALCO is held liable for damages.

WHEREFORE, the petition is partly granted. The CA decision is

affirmed with modification.