National Power Corp. v. Benguet Electric Cooperative, Inc. [G.R. No. 218378 (Resolution), June 14, 2021]

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National Power Corp. v. Benguet Electric Cooperative, Inc.

G.R. No. 218378 (Resolution), [June 14, 2021]

SECOND DIVISION, LOPEZ, M.V

 

Unjust Enrichment; Contractual Liability 

The principle of unjust enrichment under Article 22 of the Civil Code is not a catch-all provision that can be conveniently invoked when a party has suffered a loss. Unjust enrichment doesn't apply when a contract governs the relationship between parties.

 

The National Power Corporation (NPC) sought to recover underbilled power charges from Benguet Electric Cooperative, Inc. (BENECO) for a period spanning May 2000 to February 2004. The underbilling arose due to NPC's failure to use the correct Current Transformer Ratio (CTR) setting, resulting in a wrong billing multiplier for calculating electricity consumption. BENECO discovered the error in 2004 and informed NPC. NPC argued that BENECO should pay the underbilled amount to avoid unjust enrichment. But BENECO refused to pay the underbilling, arguing that NPC's negligence was the cause and that NPC's claims were waived under their Transition Contract. 

 

Is BENECO liable to pay the underbilled amount claimed by NPC under the principle of unjust enrichment. 

NO. BENECO’s liability to pay underbilled amount is based on contract and not from unjust enrichment doctrine. The Court found that the principle of unjust enrichment does not apply because a contract existed between the parties, and the claim must be based on the contract's provisions. The Transition Contract allowed NPC to correct erroneous billings within 90 days, and BENECO is liable only for the underbilling related to corrected billings within that period. 

While NPC attempted to shift blame to BENECO for not promptly detecting the error, the Court found NPC solely responsible for the error due to its negligence in maintaining accurate billing systems. The Court also affirmed BENECO's entitlement to a 3% prompt payment discount on current bills, as it had been promptly paying its current obligations. The Court emphasized the importance of diligence in public service and remanded the case to determine the exact underbilling amount during the relevant period.

 

 

 

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