Manila Electric Co. v. TEAM Corporation, G.R. No.

131723, December 13, 2007, 540 SCRA 62

Facts:
Respondent T.E.A.M. Electronics Corporation (TEC) was formerly recognized as National Semi-
Conductors (Phils.) prior to 1988 and as NS Electronics (Philippines), Inc. prior to 1982.
Respondent Technology Electronics Assembly and Management Pacific Corporation (TPC) is the
sole owner of TEC. On the other hand, the utility company Manila Electric Company (Meralco),
the petitioner, provides electricity to the Metro Manila region. Petitioner and NS Electronics
(Philippines), Inc., the predecessor-in-interest of respondent TEC, were parties to two separate
contracts denominated as Agreements for the Sale of Electric Energy.
Willie Abangan, representing Ultra, witnessed a surprise inspection of DCIM's electric meters,
revealing alleged tampering and failure to record actual power consumption, as revealed in
Service Inspection Reports. For failure of TEC to pay the differential billing, petitioner
disconnected the electricity supply to the DCIM building on April 29, 1988. TEC demanded from
petitioner the reconnection of electrical service, claiming that it had nothing to do with the
alleged tampering, but the latter refused to heed the demand.
Issue/s:
Whether or not TEC can claim for the recovery of moral damages based on alleged tampering
and failure to record actual power consumption.
Held:
Yes, the SC believed that it is appropriate to remove the moral damages award. The basis of TEC's
claim purportedly rested on the harm done to its reputation and goodwill. Because a corporation
is not a natural person and cannot feel physical pain or emotions like moral shock, serious
anxiety, mental anguish, or wounded feelings, it generally does not have the right to moral
damages. This rule is only broken in cases where the company's reputation has been damaged to
the point where it has embarrassed itself in the business world. However, in this kind of situation,
the claimant must provide evidence to support the award. It is imperative to demonstrate the
existence of the damage's factual foundation and its causal connection to the petitioner's
actions. There is no proof in the current case's records that the petitioner's actions have
damaged TEC/TPC's reputation or name. Furthermore, the trial court did not provide any
justification for its award of moral damages in the dispositive section of its ruling.