Syquia v. Board of Power & Water Works
REITERATIONFacts
1. The Antecedents: Private respondents, tenants in an apartment building managed by petitioner Caridad Cruz de Syquia, filed separate complaints against her. They alleged that Syquia was illegally selling electricity without a permit or franchise by billing them for amounts exceeding authorized Meralco rates for their individual apartment consumption during May to September 1974. Syquia contended that she was merely passing on Meralco billings, which included common area electricity costs (elevator, servants' quarters) advanced by her and reimbursed pro rata by tenants as per their lease contracts. The dispute escalated when Meralco's fuel adjustment costs, also passed on pro rata, led to the tenants' complaints. 2. Procedural History: The private respondents filed their complaints with the Board of Power and Waterworks (formerly Public Service Commission). Syquia's motion to dismiss, arguing the matter was contractual and beyond the Board's jurisdiction, was denied. She reiterated this jurisdictional challenge in her answer, asserting her role was not selling electricity but a contractual reimbursement of Meralco bills. The Board, in an order dated August 28, 1975, computed the billings to allow Syquia to charge only for electricity registered on individual meters, disallowing the pro rata charge for common area electricity. Syquia's motion for reconsideration, highlighting potential annual losses and reiterating the jurisdictional issue, was also denied by the Board. 3. The Petition: Syquia filed a petition with the Supreme Court, treating it as a special civil action, arguing that the Board of Power and Waterworks acted without jurisdiction. She contended that the dispute was purely civil, concerning lease contract conditions between a landlord and tenants, and thus fell under the exclusive jurisdiction of regular courts, not the regulatory Board. The Supreme Court, noting the transfer of jurisdiction over public services to the Board under Presidential Decree No. 1 as amended by Presidential Decree No. 458, agreed that the Board had manifestly exceeded its authority by adjudicating a matter that was contractual in nature and did not involve Syquia engaging in a public service or selling electricity without a franchise. The Court found the Board had arrogated a judicial function and its orders were null and void.
Issue(s)
Whether the respondent Board of Power and Waterworks has jurisdiction over disputes concerning the proportionate billing of electricity costs for common areas between a landlord and her tenants. Whether the respondent Board committed grave abuse of discretion in ordering the petitioner to absorb the additional costs of electricity for common areas, resulting in a financial loss.
Ruling
The Supreme Court annulled the questioned orders of the respondent Board of Power and Waterworks and ordered the dismissal of the private respondents' complaints. The Court ruled that the Board acted without jurisdiction.
Ratio Decidendi
On Issue 1: The Supreme Court held that the respondent Board of Power and Waterworks manifestly exceeded its jurisdiction in taking cognizance of and adjudicating the complaints filed by the tenants against the petitioner. The Court clarified that the dispute between the petitioner landlord and her tenants regarding the proportionate amount each tenant should bear for the common facilities used in the apartments, or whether such amounts should be borne by the tenants at all, is an issue affecting mathematical computations and conditions of lease between landlord and tenant. This matter is purely civil in character and is to be adjudged under the applicable provisions of the Civil Code, not under the Public Service Act. The Board acquired no jurisdiction over petitioner's contractual relations with her tenants because petitioner is not engaged in a public service nor in the sale of electricity without a permit or franchise. The Court noted that under the reorganization plan, jurisdiction over public services related to electric light and power utilities was transferred to the respondent board, but this did not extend to purely contractual disputes between private parties. On Issue 2: The Supreme Court ruled that the respondent Board, in resolving the complaints against the petitioner and requiring her to absorb the additional rising costs of electricity consumed for the common areas and elevator service, even at a resultant loss of P15,000.00 a year, arrogated the judicial function. The Court found that the Board's orders were beyond its jurisdiction and must be set aside as null and void. The Court emphasized that the petitioner was merely passing on legitimate electric current bills to the tenants in accordance with their lease contracts, and the issue of how these costs were apportioned was a matter of civil law, not administrative regulation. The Board's determination that the owner should solely shoulder the costs for common areas, despite contractual agreements, constituted an overreach of its regulatory powers.
Main Doctrine
The Supreme Court held that the respondent Board of Power and Waterworks exceeded its jurisdiction by taking cognizance of complaints filed by tenants against their landlord concerning the proportionate billing of electricity costs for common areas. The Court emphasized that such disputes are purely civil in character, arising from contractual obligations between landlord and tenant, and are therefore cognizable only by regular courts of general jurisdiction, not by a regulatory board tasked with overseeing public services and the sale of electricity without a franchise.