GR 182976; (January, 2013) (Digest)
G.R. No. 182976 ; January 14, 2013
MANILA ELECTRIC COMPANY (MERALCO), Petitioner, vs. ATTY. PABLITO M. CASTILLO, doing business under the trade name and style of PERMANENT LIGHT MANUFACTURING ENTERPRISES and GUIA S. CASTILLO, Respondents.
FACTS
Respondents, the Castillos, operated Permanent Light Manufacturing Enterprises. On April 19, 1994, MERALCO inspectors found their electric meter tampered—with a deformed terminal seal, fake lead cover, and a misaligned dial pointer. MERALCO immediately disconnected the service, confiscated the meter, and later demanded payment for unregistered consumption. The Castillos paid P55,538.20 to secure reconnection but contested subsequent bills, alleging the replacement meters ran faster, causing inflated charges. They filed a case for injunction and damages to prevent disconnection and recover their payments.
MERALCO claimed the meter tampering caused losses and justified its billing. The Regional Trial Court ruled for MERALCO, ordering the Castillos to pay the contested bill but also awarding them P1,138,898.86 for overpayment on subsequent bills. The Court of Appeals affirmed but deleted the overpayment award, finding it unsupported by formally offered evidence, and instead awarded P500,000 in temperate damages to the Castillos for their unquantified business losses.
ISSUE
The core issue is whether the Court of Appeals erred in deleting the award for overpaid electric bills and in awarding temperate damages to the respondents.
RULING
The Supreme Court denied MERALCO’s petition and affirmed the Court of Appeals’ decision. On the deletion of the overpayment award, the Court upheld the appellate court’s finding that the evidence for the exact amount of P1,138,898.86 was not formally offered during trial. Jurisprudence mandates that courts cannot consider evidence not formally offered. The Castillos’ failure to specify and offer their computed summaries as evidence rendered them mere scraps of paper with no probative value, justifying the deletion.
Regarding temperate damages, the Court affirmed the award of P500,000. While the Castillos could not prove their business losses with exactitude due to MERALCO’s abrupt disconnection during a critical contract fulfillment, they sufficiently established they suffered some pecuniary loss. Temperate damages are precisely awarded when some loss is proven but its exact amount cannot be ascertained from the evidence. The amount, fixed at the court’s discretion, was deemed reasonable compensation for the disruption and unquantified losses to their manufacturing business. The Court found no abuse of discretion in this award.