Case Digest (G.R. No. L-19643)
Facts:
On April 12, 1961, Froilan Japa, the respondent, submitted an application to the Public Service Commission seeking authority to operate eight TPU buses on the Legaspi-Naga City line and vice versa (Case No. 61-2694). This application faced opposition from A. L. Ammen Transportation Company, Inc., Bicol Transportation Company, Inc., and Consolidated Auto Line, Inc., the petitioners, who argued that they already provided adequate service on the same route and that granting Japa's application would lead to cut-throat competition. During the hearings, Japa and his witness, Medardo Alvarez, testified that many passengers were left behind due to the full capacity of the petitioners' buses, especially in intermediate towns. Japa demonstrated his financial capability by detailing his investments, including two stores worth P150,000, and bank deposits totaling P38,000. The petitioners countered with evidence from their Assistant Operations Manager, Felipe Abano, who claimed th...
Case Digest (G.R. No. L-19643)
Facts:
Application for TPU Bus Operation
On April 12, 1961, respondent Froilan Japa filed an application with the Public Service Commission to operate eight TPU buses on the Legaspi-Naga City route.
Opposition by Petitioners
Petitioners (A. L. Ammen Transportation Co., Inc., Bicol Transportation Company, Inc., and Consolidated Auto Line, Inc.) opposed the application, claiming they already provided adequate and satisfactory service on the route. They argued that granting the application would lead to ruinous competition.
Applicant’s Testimony
Japa and his witness, Medardo Alvarez, testified that passengers often faced difficulties boarding the petitioners’ buses, especially in intermediate towns. They also claimed that passengers had to go to the starting points of the buses to secure seats, incurring additional expenses.
Applicant’s Financial Capacity
Japa demonstrated his financial capacity by showing investments in two stores worth P150,000.00, P8,000.00 in the Philippine Savings Bank, and P30,000.00 in the Bank of Commerce, Haya Branch. He also mentioned owning a lot in Tondo, Manila, though it was not yet registered in his name.
Petitioners’ Testimony
Petitioners’ witness, Felipe Abano, testified that their buses made a combined total of 62 round trips daily on the Naga-Legaspi route. They claimed that the existing service was sufficient to meet passenger demand, even during peak hours.
Public Service Commission Decision
On February 22, 1962, the Public Service Commission granted Japa authority to operate four auto-trucks instead of the eight originally applied for. The Commission found Japa financially qualified and deemed the service necessary to replace abandoned operations and promote public interest.
Petition for Review
Dissatisfied with the decision, petitioners filed for review, alleging that the Commission abused its discretion in finding Japa financially capable and in determining that the service would promote public interest.
Issue:
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Ruling:
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Ratio:
Questions of Fact Are Conclusive on the Supreme Court
The Court reiterated that findings of fact by the Public Service Commission, based on the evaluation of evidence and credibility of witnesses, are binding and cannot be re-examined by the Supreme Court unless there is a clear absence of supporting evidence.Financial Capacity of the Applicant
The Court upheld the Commission’s finding that Japa was financially capable, noting that he had acquired and registered the four auto-trucks authorized by the Commission. His assets, totaling P188,000.00, were deemed sufficient to operate the service.Public Interest and Replacement of Abandoned Services
The Court agreed with the Commission that granting Japa’s application would promote public interest by replacing services that had been abandoned by other operators.New Evidence on Appeal
The Court refused to consider “newly discovered evidence” presented by petitioners regarding Japa’s financial difficulties during the appeal. It emphasized that only evidence presented before the Commission should be considered in determining whether its decision was supported by sufficient evidence.