The petition filed by the city government of Puerto Princesa against a local electric cooperative was junked by the Court of Appeals as it upheld a lower court’s decision that the National Electrification Administration holds supervision and control over such entities.
It affirmed the dismissal of a complaint for injunction and damages filed by the local government against the Palawan Electric Cooperative over alleged negligence leading to frequent power outages in the city.
In a 12-page decision penned by Associate Justice Emilio Rodolfo Legaspi III dated 28 November 2025, the CA’s Fourteenth Division rejected the plea for lack of merit.
“Wherefore, the Amended Petition for Certiorari is DISMISSED for lack of merit. The assailed 28 August 2020 Omnibus Order and 5 September 2022 Order of the Regional Trial Court, Branch 52, Puerto Princesa City in Civil Case No. 5886 are hereby affirmed.”
The CA likewise stated that the assailed orders of the RTC were not shown to be patently erroneous or issued in a capricious or whimsical exercise of judgment.
It held that the orders were issued in obedience to and consistent with pertinent rules and existing jurisprudence, and thus the court a quo cannot be said to have gravely abused its discretion.
Based on the decision, the Puerto Princesa RTC Branch 52 lacked jurisdiction over the original complaint, citing Section 5(q) of Republic Act 10531, or the NEA Reform Act, which vests the NEA with the authority of supervision and control over electric cooperatives.
It said that since the petitioner’s claim primarily hinged on respondents’ alleged gross negligence, inaction, and failure to provide a stable, adequate and uninterrupted supply of electricity — a cause purely administrative in nature — the RTC correctly ruled that the case should have been lodged with the NEA, as it is the agency mandated to enforce performance standards of electric cooperatives and their officers.
The court acknowledged the doctrine of primary jurisdiction, noting the specialized nature of the complaint.
“Notably, the resolution of such issues would necessarily call for the knowledge, experience and expertise of the NEA. Thus, it was but proper, out of fidelity to the doctrine of primary jurisdiction, for the RTC to dismiss petitioner’s complaint,” the CA said.
The case originated from a 2019 complaint filed by Puerto Princesa City Mayor Lucilo R. Bayron against PALECO and its board officials.
The city government sought P1 million in damages from PALECO, alleging that the “alarming and extensive power outages” caused disruption of government services and transactions, damage to the tourism industry, and breakdown of home appliances.
It argued that the cooperative and its officials failed to provide adequate, regular and reliable electricity to the residents.
On 28 August 2020, the Puerto Princesa RTC dismissed the complaint for lack of jurisdiction, and affirmed its ruling when it denied the city government’s motion for reconsideration on 5 September 2022.