Manila Paper Mills v. Manila Electric Company

Summary

Manila Paper Mills, Inc. (MPM) challenged MERALCO's differential billing claims of over P192 million for allegedly tampered electric meters from 1984-1987. MERALCO discovered defective meter installations with broken seals, pricked holes, and shorting devices during inspections in November 1987 and February 1988, causing underregistration of actual electricity consumption. Despite MPM's denial and injunction suits, all court levels found preponderant evidence of tampering based on: previous violations, drastic consumption decreases despite sales increases, technical evidence of meter manipulation, and lack of credible proof of energy conservation programs. The Supreme Court affirmed temperate damages under Civil Code Article 2224, as pecuniary loss occurred but exact amount couldn't be proven with mathematical certainty. The decision establishes that utility service contracts may allow estimated billing for unregistered consumption without requiring proof of customer-caused tampering, provided evidence shows meter failure or stoppage occurred.