GR 102184; (April, 2000) (Digest)
G.R. No. 102184 ; April 12, 2000
CAGAYAN ELECTRIC POWER AND LIGHT COMPANY, INC., petitioner, vs. CONSTANCIO F. COLLERA, et al., respondents.
FACTS
Respondents, customers of petitioner Cagayan Electric Power and Light Company, Inc. (CEPALCO), filed a complaint in the Regional Trial Court (RTC) of Misamis Oriental. They alleged that since 1977, CEPALCO had been collecting payments under the Power Adjustment Clause without deducting discounts and credit adjustments granted by the National Power Corporation. On October 1, 1985, respondents tendered payments less these disputed adjustments, which CEPALCO refused. They thus consigned the payments to court and sued for unjust enrichment, recovery of sums of money, breach of contract, and damages.
The RTC dismissed the complaint for lack of jurisdiction, holding that the subject matter fell within the exclusive jurisdiction of the Energy Regulatory Board (ERB) under Presidential Decree No. 1206. On appeal, the Court of Appeals reversed, ruling that the regular courts had jurisdiction. CEPALCO elevated the case to the Supreme Court via certiorari.
ISSUE
Whether jurisdiction over the complaint for recovery of alleged overcharges and unjust enrichment is vested in the regular courts or the Energy Regulatory Board.
RULING
The Supreme Court ruled that jurisdiction is vested in the regular courts. It affirmed the decision of the Court of Appeals. The Court clarified that while the ERB, under its charter, has the power to regulate and fix power rates for electric utilities, this authority does not extend to adjudicating claims for recovery of sums allegedly overcharged or determining whether a utility is guilty of unjust enrichment through such overcharges.
The complaint did not assail the validity of the Power Cost Adjustment or Currency Exchange Rate Adjustment rates themselves. Instead, it alleged that CEPALCO collected the full rate without corresponding cost increases, thereby unjustly enriching itself. Such a cause of action, which involves the examination of whether collected adjustments were properly applied or constituted undue profit, falls within the realm of ordinary civil disputes. The RTC, as a court of general jurisdiction, is competent to hear evidence and decide on claims for reimbursement and damages arising from contractual relations or quasi-contract. The petition was dismissed for lack of merit, and the case was remanded to the RTC for trial on the merits.