GR 109389; (June, 2006) (Digest)
G.R. No. 109389 ; June 26, 2006
MANILA ELECTRIC COMPANY, Petitioner, vs. SPOUSES HUA KIM PENG and ANGELITA RAMORAN, Respondents.
FACTS
Respondent spouses owned factories and residential units supplied with electricity by petitioner MERALCO under five separate accounts. MERALCO’s inspection team, entering the respondents’ compound in their absence, allegedly found illegal jumpers connected to an idle meter base, enabling theft of electricity. MERALCO subsequently demanded payment of over P1.8 million for alleged unregistered consumption and threatened disconnection. The spouses filed an injunction suit, asserting the jumpers were a fabrication and that MERALCO’s inspection was conducted without proper notice or consent. The Regional Trial Court dismissed the complaint and ordered the spouses to pay MERALCO’s demand.
ISSUE
Whether the Court of Appeals erred in reversing the trial court and ruling that MERALCO failed to prove by substantial evidence that the respondents illegally used jumpers to pilfer electricity.
RULING
The Supreme Court affirmed the Court of Appeals. The core legal logic rests on the burden of proof in civil cases and the evaluation of evidence. MERALCO, as the party alleging theft, carried the burden to establish its claim by substantial evidence. The Court scrutinized the photographic evidence and found it did not substantiate the allegation. The pictures showed the alleged jumpers were connected to wires after the meter, meaning any consumption would have been registered. For theft via a jumper to occur, the tap must be before the meter to bypass registration. Since MERALCO’s own evidence indicated the meters were functional and untampered, the alleged configuration could not result in unrecorded consumption. The Court found MERALCO’s demand baseless and its subsequent acts, including the intrusive inspection and threat of disconnection despite a contrary factual basis, were tainted with bad faith. This justified the award of moral and exemplary damages for the unwarranted distress and oppressive conduct, as well as attorney’s fees. The injunction against disconnection was made permanent.