Baliuag Electric v. Echiveri
REITERATIONFacts
The Antecedents: Petitioner Baliuag Electric Light and Power Co., Inc. (BELPC) held a franchise to distribute electricity and supplied power to respondent Virginio Santiago's ice plant under a contract. BELPC applied for and was granted increased electricity rates by the Public Service Commission (PSC), a decision later affirmed by the Supreme Court. Respondent Santiago filed a petition with the PSC for reclassification or readjustment of the new rates, deeming them unreasonable and exorbitant. Santiago refused to pay under the new rates, accumulating a bill of P14,733.60 as of February 16, 1972. Consequently, BELPC disconnected Santiago's power supply and filed a collection suit. Procedural History: Respondent Santiago filed a petition for mandamus with the Court of First Instance (CFI) of Bulacan, Branch IV, seeking a writ of preliminary mandatory injunction to restore his electric power. He argued that without the injunction, his petition for rate readjustment before the PSC would become moot. The respondent Judge granted the injunction upon the filing of a P15,000.00 bond, aiming to maintain the status quo. BELPC moved to dissolve the injunction, asserting Santiago lacked a clear legal right, the contract allowed disconnection for non-payment, the PSC rates were affirmed by the Supreme Court, and Santiago lacked legal personality to seek rate reclassification. The Petition: Petitioner BELPC filed a petition for certiorari and prohibition with the Supreme Court, assailing the CFI's order granting the writ of preliminary mandatory injunction. BELPC argued that the respondent judge committed grave abuse of discretion in not dismissing the case and not dissolving the injunction, given the circumstances.
Issue(s)
Whether the respondent judge committed grave abuse of discretion in issuing a writ of preliminary mandatory injunction to restore electric power to respondent Santiago's ice plant. Whether the writ of preliminary mandatory injunction issued by the respondent judge became moot and academic upon the dismissal of respondent Santiago's petition before the Public Service Commission.
Ruling
The Supreme Court lifted the writ of preliminary mandatory injunction. It ordered respondent Virginio Santiago to pay petitioner all his past electric bills in accordance with the approved rates within ninety (90) days from the determination of the amount by the Court of First Instance in the collection suit (Civil Case No. 328-B), otherwise, petitioner may enforce payment by execution and disconnect the electric power.
Ratio Decidendi
On Issue 1: The Supreme Court found that the respondent judge did not commit grave abuse of discretion in issuing the writ of preliminary mandatory injunction, as the intention was to maintain the status quo between the parties pending the resolution of the rate adjustment petition before the Public Service Commission (PSC). The judge considered the potential damages to both parties and required a bond to protect their interests. The issuance was aimed at preserving the subject matter of the dispute until a final determination by the proper agency. However, the subsequent dismissal of Santiago's petition before the PSC rendered the injunction's purpose moot. On Issue 2: The Supreme Court held that the writ of preliminary mandatory injunction issued by the respondent judge became moot and academic upon the dismissal of respondent Santiago's petition for readjustment of electric rates before the Board of Power and Waterworks (formerly the PSC). The writ was intended to be effective only during the pendency of Santiago's petition, and its dissolution was a natural consequence of the petition's dismissal. This rendered the injunction functus officio, meaning it had fulfilled its purpose or lost its legal effect. Consequently, the collection suit filed by petitioner BELPC also became moot, except for the determination of the exact amount Santiago owed.
Main Doctrine
The Supreme Court held that a writ of preliminary mandatory injunction, issued by the Court of First Instance to restore electric power to an ice plant pending the resolution of a petition for rate readjustment before the Public Service Commission (PSC), becomes moot and academic once the PSC dismisses the petition. The injunction's purpose was to preserve the status quo until the PSC decided the rate case, and its dissolution was a natural consequence of the petition's dismissal, rendering the collection suit also moot except for the determination of the amount due.