FACTS:
MERALCO is a corporation duly organized and existing under Philippine laws engaged in the distribution and sale of electric power in Metro Manila. On the other hand, BF Homes and PWCC are owners and operators of waterworks systems delivering water to over 12,000 households and commercial buildings in BF Homes subdivisions in Paranaque City, Las Pinas City, Caloocan City, and Quezon City. The water distributed in the waterworks systems owned and operated by BF Homes and PWCC is drawn from deep wells using pumps run by electricity supplied by MERALCO.
In June 2003, MERALCO demanded for unpaid bills, but petitioners refused invoking their right to refund based on the 2002 SC ruling in Republic vs. Manila Electric Company ordering MERALCO to refund its customers.
When its repeated demands remained unheeded, MERALCO, threatened to cut off electric power to all petitioners' pumps if bills remained unpaid. Thus on, petitioners filed a petition in RTCLas Piñas with prayer for issuance of writ of injunction and restraining order against MERALCO alleging that it refused to set off the P4.7M unpaid bills against the P11.8M amount refundable to petitioners based on the cited ruling.
MERALCO in its Answer, argued that RTC has no jurisdiction over the case on the ground that matters regarding the guidelines, schedules and details of refund is under the authority and approval of Energy Regulatory Commission (ERC), MERALCO's regulatory agency, as provided by law and the cited ruling. It likewise opposed the issuance of the writ.
RTC granted the application for the issuance of writ of injunction. When its motion to reconsider was denied, MERALCO appealed to CA. The CA reversed RTC decision thereby dissolving the writ of injunction. When their motion for reconsideration was denied, petitioners filed the present petition for review on certiorari under Rule 45.
ISSUE:
Whether or not the jurisdiction over this matter lies with the RTC.
HELD:
No. A careful review of the material allegations of BF Homes and PWCC in their Petition before the RTC reveals that the very subject matter thereof is the off-setting of the amount of refund they are supposed to receive from MERALCO against the electric bills they are to pay to the same company. This is squarely within the primary jurisdiction of the ERC.
It bears to stress that in the MERALCO Refund cases, this Court only affirmed the decision of the ERB (predecessor of the ERC) fixing the just and reasonable rate for the electric services of MERALCO and granting refund to MERALCO consumers of the amount they overpaid. Said Decision was rendered by the ERB in the exercise of its jurisdiction to determine and fix the just and reasonable rate of power utilities such as MERALCO.
Presently, the ERC has original and exclusive jurisdiction under Rule 43(u) of the EPIRA over all cases contesting rates, fees, fines, and penalties imposed by the ERC in the exercise of its powers, functions and responsibilities, and over all cases involving disputes between and among participants or players in the energy sector.
Indubitably, the ERC is the regulatory agency of the government having the authority and supervision over MERALCO. Thus, the task to approve the guidelines, schedules, and details of the refund by MERALCO to its consumers, to implement the judgment of this Court in the MERALCO Refund cases, also falls upon the ERC.
By filing their Petition before the RTC, BF Homes and PWCC intend to collect their refund without submitting to the approved schedule of the ERC, and in effect, enjoy preferential right over the other equally situated MERALCO consumers.
Administrative agencies, like the ERC, are tribunals of limited jurisdiction and, as such, could wield only such as are specifically granted to them by the enabling statutes.
In relation thereto is the doctrine of primary jurisdiction involving matters that demand the special competence of administrative agencies even if the question involved is also judicial in nature. Courts cannot and will not resolve a controversy involving a question within the jurisdiction of an administrative tribunal, especially when the question demands the sound exercise of administrative discretion requiring special knowledge, experience and services of the administrative tribunal to determine technical and intricate matters of fact. The court cannot arrogate into itself the authority to resolve a controversy, the jurisdiction of which is initially lodged with the administrative body of special competence.
Since the RTC had no jurisdiction over the Petition of BF Homes and PWCC in Civil Case No. 03-0151, then it was also devoid of any authority to act on the application of BF Homes and PWCC for the issuance of a writ of preliminary injunction contained in the same Petition. The ancillary and provisional remedy of preliminary injunction cannot exist except only as an incident of an independent action or proceeding.
Lastly, the Court herein already declared that the RTC not only lacked the jurisdiction to issue the writ of preliminary injunction against MERALCO, but that the RTC actually had no jurisdiction at all over the subject matter of the Petition of BF Homes and PWCC in Civil Case No. 03-0151. Therefore, in addition to the dissolution of the writ of preliminary injunction issued by the RTC, the Court also deems it appropriate to already order the dismissal of the Petition of BF Homes and PWCC in Civil Case No. 03-0151 for lack of jurisdiction of the RTC over the subject matter of the same.
No. A careful review of the material allegations of BF Homes and PWCC in their Petition before the RTC reveals that the very subject matter thereof is the off-setting of the amount of refund they are supposed to receive from MERALCO against the electric bills they are to pay to the same company. This is squarely within the primary jurisdiction of the ERC.
It bears to stress that in the MERALCO Refund cases, this Court only affirmed the decision of the ERB (predecessor of the ERC) fixing the just and reasonable rate for the electric services of MERALCO and granting refund to MERALCO consumers of the amount they overpaid. Said Decision was rendered by the ERB in the exercise of its jurisdiction to determine and fix the just and reasonable rate of power utilities such as MERALCO.
Presently, the ERC has original and exclusive jurisdiction under Rule 43(u) of the EPIRA over all cases contesting rates, fees, fines, and penalties imposed by the ERC in the exercise of its powers, functions and responsibilities, and over all cases involving disputes between and among participants or players in the energy sector.
Indubitably, the ERC is the regulatory agency of the government having the authority and supervision over MERALCO. Thus, the task to approve the guidelines, schedules, and details of the refund by MERALCO to its consumers, to implement the judgment of this Court in the MERALCO Refund cases, also falls upon the ERC.
By filing their Petition before the RTC, BF Homes and PWCC intend to collect their refund without submitting to the approved schedule of the ERC, and in effect, enjoy preferential right over the other equally situated MERALCO consumers.
Administrative agencies, like the ERC, are tribunals of limited jurisdiction and, as such, could wield only such as are specifically granted to them by the enabling statutes.
In relation thereto is the doctrine of primary jurisdiction involving matters that demand the special competence of administrative agencies even if the question involved is also judicial in nature. Courts cannot and will not resolve a controversy involving a question within the jurisdiction of an administrative tribunal, especially when the question demands the sound exercise of administrative discretion requiring special knowledge, experience and services of the administrative tribunal to determine technical and intricate matters of fact. The court cannot arrogate into itself the authority to resolve a controversy, the jurisdiction of which is initially lodged with the administrative body of special competence.
Since the RTC had no jurisdiction over the Petition of BF Homes and PWCC in Civil Case No. 03-0151, then it was also devoid of any authority to act on the application of BF Homes and PWCC for the issuance of a writ of preliminary injunction contained in the same Petition. The ancillary and provisional remedy of preliminary injunction cannot exist except only as an incident of an independent action or proceeding.
Lastly, the Court herein already declared that the RTC not only lacked the jurisdiction to issue the writ of preliminary injunction against MERALCO, but that the RTC actually had no jurisdiction at all over the subject matter of the Petition of BF Homes and PWCC in Civil Case No. 03-0151. Therefore, in addition to the dissolution of the writ of preliminary injunction issued by the RTC, the Court also deems it appropriate to already order the dismissal of the Petition of BF Homes and PWCC in Civil Case No. 03-0151 for lack of jurisdiction of the RTC over the subject matter of the same.
