Case Digest No.

33
Case: Quisumbing vs. MERALCO
G.R. No. 142943 | April 3, 2002
Ponente: J. Panganiban

FACTS:

The Quisumbings sued MERALCO for damages, alleging that MERALCO had wrongfully disconnected
their electric service and caused harm to their reputation and business. The trial court ruled in favor of
the Quisumbings, but the Court of Appeals reversed the decision. MERALCO states that spouses
Quisumbing tampared the electric meter and demanded to pay the amount of P178,875.01.

ISSUE:

1. Whether the Spouses Quisumbing are entitled to damages?

HELD:

1. the Supreme Court ruled that the petitioners were not entitled to actual damages due to
insufficient evidence. However, they were awarded moral and exemplary damages, along with
attorney's fees, as a result of MERALCO's improper disconnection of their electrical service without due
process. In this case Art. 2219 of the NCC applies which states the recovery of moral damages when the
rights of an individual are violated. Moral damages include physical and emotional suffering, as well as
damage to reputation and social standing. To recover moral damages, the plaintiff must prove four
things: 1. An injury was sustained, whether physical, mental, or psychological. 2. The defendant's act or
omission was culpable. 3. The defendant's act or omission was the proximate cause of the plaintiff's
injury. 4. The award of moral damages is authorized by Article 2219 of the Civil Code. Even though moral
damages are difficult to quantify, they can be recovered if they are the proximate result of the
defendant's wrongful act or omission.