GR 171624; (December, 2010) (Digest)
G.R. No. 171624; December 6, 2010
BF HOMES, INC. and the PHILIPPINE WATERWORKS AND CONSTRUCTION CORP., Petitioners, vs. MANILA ELECTRIC COMPANY, Respondent.
FACTS
Petitioners BF Homes, Inc. and Philippine Waterworks and Construction Corporation (BF Homes/PWCC) operate waterworks systems supplying numerous subdivisions, relying on electric pumps powered by respondent Manila Electric Company (MERALCO). BF Homes/PWCC, invoking the Supreme Court’s final ruling in the “MERALCO Refund cases” (G.R. No. 141314), claimed a refund credit of over Php 11 million from MERALCO for alleged overcharges. When MERALCO demanded payment of current electric bills and subsequently disconnected power to several water pumps for non-payment, BF Homes/PWCC requested that their current bills be offset against the refund. MERALCO refused, stating it had not yet finalized a schedule for refunding large amounts.
BF Homes/PWCC filed a Petition with the Regional Trial Court (RTC) of Las Piñas, seeking to compel the offset, for reconnection, and for damages, alongside a prayer for a writ of preliminary injunction. The RTC granted the injunction, ordering MERALCO to restore power. MERALCO challenged this via a Petition for Certiorari with the Court of Appeals.
ISSUE
Whether the Regional Trial Court had jurisdiction over the subject matter of the action filed by BF Homes/PWCC.
RULING
The Supreme Court ruled that the RTC had no jurisdiction. The legal logic is anchored on the doctrine of primary jurisdiction. The issue at the core of BF Homes/PWCC’s complaint—the implementation of the Supreme Court-ordered refund, including the manner, timing, and mechanics of crediting it against current bills—is not a simple matter of contract enforcement. It is a highly technical question involving rate-fixing and the public utility’s implementation of a regulatory order, which falls under the specialized competence of the Energy Regulatory Commission (ERC), formerly the Energy Regulatory Board.
The Court clarified that while the Supreme Court’s decision in the refund cases was final regarding MERALCO’s liability to refund, the actual execution and procedural details of that refund are administrative in nature. The law vests the ERC with exclusive original jurisdiction over all cases involving the rates and services of public utilities. Therefore, BF Homes/PWCC’s proper recourse was to seek relief from the ERC, not the RTC. Since jurisdiction over the subject matter is conferred by law and cannot be waived, the RTC’s orders, including the injunction, were void. The Supreme Court affirmed the Court of Appeals’ decision to nullify the RTC’s orders and modified it by directing the RTC to dismiss the petition for lack of jurisdiction.