G.R. No. L-13016. May 31, 1961.
AMELIA C. YUTUK, plaintiff-appellee, vs. MANILA ELECTRIC COMPANY, defendant-appellant.

FACTS

Amelia Yutuk, a lawyer, occupied a residence in Parañaque in December 1954, where Meralco retained the electric service. On October 13, 1955, Meralco meter inspector Eliseo Jaime arrived at her home. Despite Yutuk’s initial refusal to allow him entry, as the meter was installed outside, Jaime borrowed a chair, stood on it, and disconnected the meter, cutting off the power. When confronted, Jaime accused Yutuk of stealing electricity by using a “jumper.” Yutuk, who was convalescing from bronchopneumonia, indignantly denied the charge. Jaime persisted with the accusation, stating he would ensure her future bills would be higher as punishment. This incident caused Yutuk to suffer a relapse.
Subsequently, Meralco demanded payment from Yutuk for P254.40, representing allegedly unregistered consumption, and threatened disconnection. Yutuk filed a civil action for injunction and moral damages. Prior to this, Yutuk had filed a slander case against Jaime, resulting in his conviction. In retaliation, Meralco filed a criminal complaint for theft of electricity against Yutuk, which was later dismissed by the fiscal for lack of evidence.

ISSUE

Whether Meralco is liable for damages arising from the wrongful acts of its employee, Jaime, and its subsequent filing of a baseless criminal complaint against Yutuk.

RULING

Yes, Meralco is liable for damages. The Court found that Jaime’s acts were wrongful and reckless. His method of inspection was irregular, and his public accusation of theft against Yutuk, made without sufficient basis and in a manner intended to humiliate, was clearly improper. Meralco, by inferentially approving Jaime’s behavior through its subsequent actions and by choosing to file a criminal complaint instead of a civil suit to recover the alleged unpaid amount, demonstrated malice and a perversion of judicial process. The criminal charge was used as a coercive tool to force payment, not to pursue a bona fide claim.
The law protects the right to litigate, and erroneous exercise thereof does not automatically incur liability for damages. However, the evidence established that Meralco’s acts were not merely erroneous but were done with recklessness and ill-will. These acts directly caused Yutuk mental anguish, anxiety, besmirched reputation, and social humiliation, warranting an award of damages. The trial court’s award of moral damages was reduced from P250,000 to P25,000, considering Yutuk’s circumstances and the injury suffered. Exemplary damages of P10,000 and attorney’s fees of P5,000 were also awarded to serve as a deterrent. The decision was affirmed with modifications.