G.R. No. L-44190 October 30, 1980
MANILA GAS CORPORATION, petitioner-appellant, vs. COURT OF APPEALS and ISIDRO M. ONGSIP, respondents-appellees.

FACTS

Private respondent Isidro M. Ongsip was a customer of petitioner Manila Gas Corporation. In August 1966, petitioner’s employees, without prior notice to Ongsip, entered his premises, replaced his gas meter, and later accused him of having an illegal bypass valve or “jumper,” demanding money under threat of deportation. Ongsip refused. Subsequently, the new meter registered a high consumption, and petitioner filed a criminal complaint for qualified theft against Ongsip and later disconnected his gas service for alleged non-payment of bills. The Pasay City Fiscal dismissed the criminal complaint, finding no evidence of an illegal installation, as no excavation was conducted to verify the alleged jumper.
Following the dismissal, Ongsip filed a civil case for damages against Manila Gas Corporation. His complaint alleged two causes of action: first, the malicious filing of the baseless criminal complaint causing him mental anguish and social humiliation; and second, the illegal disconnection of his gas service without the required notice, done to further harass and humiliate him. The trial court ruled in favor of Ongsip, awarding damages, and the Court of Appeals affirmed the decision.

ISSUE

Whether Manila Gas Corporation is liable for damages arising from its acts of filing a criminal complaint and disconnecting gas service.

RULING

Yes, the Supreme Court affirmed the liability of Manila Gas Corporation for damages. The legal logic rests on the principle that a person who willfully causes injury to another in a manner contrary to morals, good customs, or public policy must compensate for damages under Article 21 of the Civil Code. For the first cause of action, the filing of the criminal complaint was deemed malicious. The fiscal’s dismissal, due to a complete lack of evidence—notably, the failure to excavate and physically verify the alleged illegal connection—demonstrated the complaint’s baselessness. This malicious prosecution warranted an award of moral and exemplary damages.
For the second cause of action, the disconnection was illegal. The contract required a 72-hour written notice for disconnection due to non-payment. The Court found no such notice was served on Ongsip. This procedural violation, coupled with the context of the prior harassment, indicated the disconnection was part of a scheme to further humiliate Ongsip, constituting willful injury. While Ongsip admitted being in default, this did not justify the denial of his right to notice or negate the claim for damages; it was merely a mitigating factor in quantifying the award. Consequently, the Court modified the amounts but sustained the awards for moral and exemplary damages, as well as attorney’s fees.