Cagayan Electric Power and Light Company, Inc. v. Collera
REITERATIONFacts
The Antecedents: Respondents, customers of petitioner Cagayan Electric Power and Light Company, Inc. (CEPALCO), alleged that since 1977, CEPALCO collected payments for electric consumption under the Power Adjustment Clause without deducting discounts and credit adjustments from the National Power Corporation. On October 1, 1985, respondents tendered payments less these adjustments, which CEPALCO refused to accept, leading respondents to consign the payments with the court. Procedural History: Respondents filed a complaint with the Regional Trial Court (RTC) of Misamis Oriental for unjust enrichment, recovery of sums of money, recovery of customers' deposits, breach of contract, consignation, injunction, and damages. The City of Cagayan de Oro filed a complaint in intervention. The RTC denied the application for preliminary injunction and subsequently dismissed the complaint and intervention, ruling that it lacked jurisdiction over the subject matter, which it deemed to be within the exclusive jurisdiction of the Energy Regulatory Board (ERB) under Presidential Decree No. 1206. The RTC denied the motion for reconsideration. Respondents appealed to the Court of Appeals (CA). The Petition: The Court of Appeals set aside the RTC's dismissal orders, affirming the denial of the preliminary injunction, and remanded the case to the RTC for further proceedings. CEPALCO filed a petition for certiorari with the Supreme Court, questioning the CA's ruling on jurisdiction.
Issue(s)
Whether the regular courts or the Energy Regulatory Board (ERB) has jurisdiction over a dispute involving the recovery of sums of money collected by electric power plants from consumers; and whether the RTC erred in dismissing the complaint for lack of jurisdiction.
Ruling
The Supreme Court dismissed the petition for lack of merit and affirmed the decision of the Court of Appeals, directing the trial court to expedite proceedings.
Ratio Decidendi
On the issue of jurisdiction: The Court ruled that the regional trial court has jurisdiction over the subject matter of the complaint. The RTC is a court of general jurisdiction. While Republic Act No. 6173, as amended by Presidential Decree No. 1206, empowered the ERB to regulate and fix power rates, this power does not extend to determining whether an electric company is guilty of overcharging customers. Such a determination, which involves the breakdown and itemization of power adjustment bills and allegations of unjust enrichment or breach of contract, falls within the competence of the regular courts. The Court reiterated its ruling in Manila Electric Company vs. Court of Appeals that the question of determining the breakdown and itemization of power adjustment billed by an electric power company is not a matter within the ERB's jurisdiction to regulate and fix power rates, but rather falls within the jurisdiction of the regular courts. If the petitioner indeed used deposits, discounts, surcharges, PCA, and CERA rates to obtain undue profits, respondents may have valid causes of action to be litigated before the regular courts based on presented evidence. Therefore, the dismissal of the complaint by the RTC for lack of jurisdiction was erroneous, and the CA correctly remanded the case for trial on the merits.
Main Doctrine
The regional trial court has jurisdiction over actions for recovery of sums of money collected by electric power plants from consumers, including disputes over the breakdown and itemization of power adjustment charges, as the power to fix rates does not inherently grant the Energy Regulatory Board (ERB) the authority to determine overcharging or unjust enrichment, which falls under the competence of regular courts.