GR 149052; (August, 2005) (Digest)
G.R. No. 149052 . August 9, 2005
VIBRAM MANUFACTURING CORPORATION, Petitioner, vs. MANILA ELECTRIC COMPANY, Respondent.
FACTS
Vibram Manufacturing Corporation, a shoe parts manufacturer, is a customer of Manila Electric Company (MERALCO). In 1991, MERALCO demanded payment from Vibram for over ₱1.4 million, representing alleged unregistered electrical consumption from September 1990 to September 1991 due to a defective meter. Vibram refused to pay, asserting the defect was MERALCO’s responsibility. Faced with a disconnection threat, Vibram filed a complaint for damages with a prayer for injunction.
The Regional Trial Court ruled in favor of Vibram, making the injunction permanent and awarding exemplary damages and attorney’s fees. On appeal, the Court of Appeals affirmed with modification. It held the service agreement was a valid contract of adhesion and found MERALCO negligent for failing to inspect and repair the defective meter, which caused the unregistered consumption. Applying the equitable solution from Ridjo Tape & Chemical Corp. v. CA, the appellate court ordered Vibram to pay MERALCO ₱352,067.15, representing the average consumption for the three months prior to the disputed period, to prevent unjust enrichment. It deleted the awards for exemplary damages and attorney’s fees for lack of basis.
ISSUE
Whether the Court of Appeals erred in its factual findings and in ordering Vibram to pay for unregistered electricity consumption.
RULING
The Supreme Court denied the petition and affirmed the Court of Appeals’ Decision. The Court emphasized that the petition raised factual issues, which are generally beyond the scope of a petition for review on certiorari. Factual findings of the Court of Appeals, especially when supported by evidence and affirming the trial court, are binding and conclusive upon the Supreme Court.
The legal logic rests on the principle that the Supreme Court is not a trier of facts. Its function is limited to reviewing errors of law, not re-evaluating evidence. The Court found no compelling reason to deviate from this doctrine, as petitioner failed to demonstrate that the case fell under any recognized exception. Consequently, the factual conclusions of the Court of Appeals—including its determination of MERALCO’s negligence, the validity of the contract of adhesion, and the equitable computation of Vibram’s liability based on average consumption—were upheld. The deletion of the damages awards was also sustained due to the absence of factual and legal justification for them in the body of the lower court’s decision.