G.R. No. 205035 November 16, 2016
SPOUSES GEMINO C. MIANO, JR. and JULIET MIANO, Petitioners vs. MANILA ELECTRIC COMPANY [MERALCO], Respondents

FACTS

Petitioners Spouses Miano are customers of respondent MERALCO. In March 2002, MERALCO personnel inspected the spouses’ two electric meters and discovered jumpers on the meter service connection for their residence. MERALCO disconnected the service for the residence and issued a billing differential of ₱422,185.20 for unbilled consumption. Later in December 2002, MERALCO also disconnected the service for their sari-sari store, finding an illegal connection from the store to the residence. MERALCO refused reconnection due to non-payment of the differential.
The Spouses Miano filed a Complaint for damages and injunction. The Regional Trial Court dismissed their complaint and ordered them to pay the billing differential. On appeal, the Court of Appeals modified the ruling, ordering MERALCO to pay moral and exemplary damages plus attorney’s fees for its failure to notify prior to disconnection, and to restore the electric connection. However, the appellate court sustained the order for the spouses to pay the ₱422,185.20 billing differential.

ISSUE

Whether the Court of Appeals erred in ordering the Spouses Miano to pay the billing differential of ₱422,185.20.

RULING

The Supreme Court denied the petition. The sole issue raised by the petitioners—the propriety of the billing differential—is a question of fact, not a question of law. A petition for review under Rule 45 of the Rules of Court must raise only questions of law. A question of law exists when the doubt concerns the correct application of law to established facts. In contrast, a question of fact exists when the issue requires a re-evaluation of the evidence, such as the credibility of witnesses or the existence of circumstances, to determine the truth.
Here, the petitioners are asking the Court to re-examine the evidence concerning the discovery of the jumpers and the computation of the unbilled consumption. This falls squarely within the realm of factual review. The Supreme Court is not a trier of facts; its function is not to re-analyze or weigh evidence already considered by the lower courts. The findings of fact by the Court of Appeals, especially when they affirm the trial court, are generally binding and conclusive. The petitioners failed to demonstrate that their case falls under any recognized exception to this rule, such as a gross misapprehension of facts or findings grounded on speculation. Consequently, the Court upheld the factual finding of the Court of Appeals that the billing differential was validly imposed.