Title
A.L. Ammen Transportation Co., Inc. vs. Public Service Commission
Case
G.R. No. 40264
Decision Date
Oct 20, 1933
A. L. Ammen Transportation contested PSC fees for truck substitutions, claiming no legal basis. Supreme Court ruled fees unauthorized; petitioner exhausted remedies.
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Case Digest (G.R. No. 40264)

Facts:

  1. 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.
  2. 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.
  3. 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.
  4. 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:

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Ruling:

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Ratio:

  1. 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.
  2. 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.
  3. 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).


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