Velasco v. Manila Electric

Summary

This Supreme Court En Banc resolution addressed motions for reconsideration in a noise nuisance case between Pedro Velasco and Manila Electric Company. Velasco sought increased damages, arguing his undeclared BIR-assessed income should be included in damage computation and that inflation warranted higher awards. The Court denied this, finding the undeclared income abnormally high and likely fraudulent, and Civil Code Article 1250 inapplicable to tort obligations. Meralco sought to invoke inverse condemnation doctrine and increase permitted sound levels from 50 to 55 decibels. The Court rejected both requests, ruling inverse condemnation was improperly raised and that nighttime noise reduction remained necessary for residential peace. The resolution demonstrates careful judicial analysis of damage computation principles and procedural limitations on raising new theories during reconsideration proceedings.