Case Digest (G.R. No. 40264)
Facts:
The case involves A. L. Ammen Transportation Co., Inc. as the petitioner and the Public Service Commission as the respondent. The events leading to this case began when the petitioner, a holder of several certificates of public convenience and necessity, engaged in the operation of auto-trucks across various provinces in the Philippines. In accordance with the rules set by the Public Service Commission, the petitioner sought authorization to substitute old and unserviceable trucks with new ones. Historically, the Commission charged a uniform fee for the issuance of such orders, equivalent to the fee for a new certificate of public convenience and necessity. This practice was based on Section 27 of Act No. 3108, as amended by Act No. 3418, which outlined fixed fees for services rendered by the Commission.
In one specific instance, the petitioner requested to replace 30 old one-ton trucks with 30 new 1 1/3 ton trucks. The Public Service Commission, however, sought to impose ...
Case Digest (G.R. No. 40264)
Facts:
Background of the Case:
- The petitioner, A. L. Ammen Transportation Co., Inc., is the holder of several certificates of public convenience and necessity. It operates auto-trucks in various provinces in the Philippines.
- The Public Service Commission (PSC) requires operators to seek authorization when substituting old and unserviceable trucks with new ones.
Fee Dispute:
- The PSC charged the petitioner a fee for approving the substitution of trucks, equating it to the fee for issuing a new certificate of public convenience and necessity.
- The fee was based on Section 27(b) of Act No. 3108, as amended by Act No. 3418, which specifies fees for certificates covering the operation of motor vehicles.
Specific Incident:
- In Case No. 20483, the petitioner sought to substitute 30 old one-ton trucks with 30 new 1½-ton or 1⅓-ton trucks.
- The PSC charged the petitioner P300 for the approval order, which the petitioner contested as unauthorized by law.
Procedural History:
- The petitioner requested reconsideration of the PSC's decision multiple times, including on July 20, 1931, and January 26, 1933.
- After correspondence and a hearing on August 8, 1933, the PSC reaffirmed its decision on August 16, 1933.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Statutory Interpretation:
- Section 27(b) of Act No. 3108, as amended, clearly and precisely specifies fees for the issuance of certificates of public convenience and necessity. It does not authorize fees for orders approving the substitution of trucks.
- The PSC's imposition of fees for such orders exceeded its statutory authority.
Exhaustion of Administrative Remedies:
- The petitioner had made multiple requests for reconsideration and engaged in extensive correspondence with the PSC, demonstrating compliance with the requirement to exhaust administrative remedies.
- A further application for rehearing was deemed unnecessary under the circumstances.
Legal Authority for Fees:
- Fees charged by the PSC must be explicitly authorized by law. Since the statute did not provide for fees related to the substitution of trucks, the PSC's actions were ultra vires (beyond its legal authority).