GR 109853; (October, 2000) (Digest)
G.R. No. 109853; October 11, 2000
PROVINCE OF ZAMBOANGA DEL NORTE, represented by GOV. ISAGANI S. AMATONG, petitioner, vs. COURT OF APPEALS and ZAMBOANGA DEL NORTE ELECTRIC COOPERATIVE, INC., respondents.
FACTS
The Province of Zamboanga del Norte filed a complaint with the Regional Trial Court (RTC) against Zamboanga del Norte Electric Cooperative, Inc. (ZANECO) for “Illegal Collection of Power Bills.” The complaint alleged that ZANECO arbitrarily increased its Fuel Compensating Charge (FCC) and Interim Adjustment, effectively doubling consumers’ bills. The Province contended these increases were illegal as they lacked sanction from the Energy Regulatory Board (ERB) and were implemented despite a Supreme Court restraining order on a related rate hike from the National Power Corporation.
ZANECO moved to dismiss the case, arguing the RTC lacked jurisdiction. The RTC denied the motion, ruling the action involved matters not capable of pecuniary estimation and that resort to administrative agencies like the National Electrification Administration (NEA) would be futile. The Court of Appeals reversed the RTC, ordering the dismissal of the complaint. Hence, this petition.
ISSUE
Whether the Regional Trial Court has jurisdiction over the complaint questioning the legality of power rate increases imposed by an electric cooperative.
RULING
No, the Regional Trial Court does not have jurisdiction. The Supreme Court affirmed the Court of Appeals’ decision, holding that the National Electrification Administration (NEA) possesses primary jurisdiction over the complaint. The core issue was the legality of ZANECO’s increased charges (FCC/ICC), which is fundamentally a question of power rate regulation. Under Presidential Decree No. 269, as amended, the NEA is vested with the exclusive power to regulate and fix the rates charged by electric cooperatives. This jurisdiction was not divested by the subsequent creation of the Energy Regulatory Board (ERB) under Executive Order No. 172, as the ERB’s authority pertains to the regulation of petroleum product prices, not the direct regulation of rates charged by electric cooperatives to end-users.
The Court emphasized the doctrine of primary jurisdiction, which mandates that where a specialized administrative agency has expertise over a dispute, the courts must defer to that agency. The complaint required a technical determination of the reasonableness and propriety of the rate adjustments, a matter within NEA’s competence. The petitioner’s failure to exhaust this administrative remedy was fatal to its court action. The case was therefore correctly dismissed for lack of jurisdiction, and the proper recourse for the Province was to seek relief first from the NEA.