1) Private respondents filed a complaint against their landlord, Syquia, with the Board of Power and Waterworks claiming Syquia was selling electricity without a permit and charging rates above Meralco.
2) Syquia argued the board did not have jurisdiction as she was merely passing electricity costs to tenants according to their lease contracts, making it a civil contractual matter.
3) The board ruled it had jurisdiction but only allowed Syquia to charge individual apartment meter costs, disallowing additional charges for common areas. Syquia petitioned questioning the board's jurisdiction.
Original Description:
Syquia vs Board of Power and Waterworks Case Digest Administrative Law Quasi-Judicial Function
Original Title
Syquia vs Board of Power and Waterworks Case Digest
1) Private respondents filed a complaint against their landlord, Syquia, with the Board of Power and Waterworks claiming Syquia was selling electricity without a permit and charging rates above Meralco.
2) Syquia argued the board did not have jurisdiction as she was merely passing electricity costs to tenants according to their lease contracts, making it a civil contractual matter.
3) The board ruled it had jurisdiction but only allowed Syquia to charge individual apartment meter costs, disallowing additional charges for common areas. Syquia petitioned questioning the board's jurisdiction.
1) Private respondents filed a complaint against their landlord, Syquia, with the Board of Power and Waterworks claiming Syquia was selling electricity without a permit and charging rates above Meralco.
2) Syquia argued the board did not have jurisdiction as she was merely passing electricity costs to tenants according to their lease contracts, making it a civil contractual matter.
3) The board ruled it had jurisdiction but only allowed Syquia to charge individual apartment meter costs, disallowing additional charges for common areas. Syquia petitioned questioning the board's jurisdiction.
Doctrine: the additional electricity cost for common facilities of the apartment building used by the tenants in common is purely civil in character, (involving the conditions of lease between landlord and tenant), to be adjudged under the applicable civil laws exclusively by the regular courts of general jurisdiction and is beyond the jurisdiction of respondent board. Facts: Private respondents(Ruiz, Enriquez, and Moses) filed a complaint to the Board of Power and Waterworks charging Syquia, their landlord, of selling electricity without permit or franchise and billing them for amounts in excess of Meralco rates. Petitioner Syquia questioned the jurisdiction of the regulatory board(respondent) contending that she is not engaged in the sale of electric power but merely passes to the end-users their legitimate electric current bills in accordance to their lease contract.(basically contractual in nature ang meron siya sa tenant at pinapasa lang nya yung mga bills) Respondent Board in its re-computation allowed petitioner to charge respondents only the cost of electricity registered in their individual apartment meters and disallow the actual cost of additional electricity charged them pro rata by petitioner for the cost of electricity consumed by all tenants in the common areas. Hence, the petition. Issue: Whether or not the Board of Power and Waterworks has jurisdiction. Held: No.The Board of Power and Waterworks has exceeded its jurisdiction. Petitioner is not engaged in a public service nor in the sale of electricity without permit or franchise. The complaint by the tenant give rise to a question that is purely civil in character that is to be adjudged under the applicable provisions of the Civil Code (not the Public Service Act) and not by the respondent regulatory board which has no jurisdiction but by the regular courts of general jurisdiction.