Title
A. L. Ammen Transportation Co., Inc. vs. Rayala
Case
G.R. No. L-10371
Decision Date
May 30, 1960
PSC granted regular certificates despite opposition, citing population growth, economic development, and increased demand for transportation services.
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Case Digest (G.R. No. L-10371)

Facts:

Background of the Case

  • The case involves two petitions: G.R. No. L-10371 and G.R. No. L-10409.
  • In G.R. No. L-10371, the respondent, Daniel Rayala, held an emergency certificate of public convenience to operate an auto-truck service over the Oas (Albay) lines. He applied to the Public Service Commission (PSC) to convert this emergency certificate into a regular one.
  • The petitioner, A. L. Ammen Transportation Co., Inc., opposed the application, arguing that it had already resumed its pre-war operations with 263 units in 1952, and the conditions justifying the emergency certificate no longer existed.
  • The PSC granted the respondent's application, prompting the petitioner to appeal.

Evidence Presented by the Respondent

  • The respondent presented evidence showing:
    • Heavy traffic on market days throughout the week, with buses filled with passengers and freight.
    • Increased student travel to schools and colleges in the morning and returning in the afternoon.
    • Growth in commercial and industrial activities in Albay and Camarines Sur.
    • Migration of laborers from Albay to Camarines Sur during harvest seasons.
    • Increased population necessitating more transportation facilities.

Evidence Presented by the Petitioner

  • The petitioner, through its Assistant Traffic Manager, argued:
    • The respondent was not profiting from his transportation business, as evidenced by a certification from the municipal treasurer of Oas.
    • The petitioner had already restored its pre-war fleet of 263 units, making the respondent's emergency certificate unnecessary.

Condition in the Emergency Certificate

  • The emergency certificate issued to the respondent included a condition that the PSC reserved the right to alter or modify the certificate based on changing conditions and the eventual resumption of normal operations.

G.R. No. L-10409

  • In this related case, the respondent, Enrique de Leon, held a five-year certificate of public convenience to operate an auto-truck service over several lines in Camarines Norte. He applied for a renewal of this certificate.
  • The petitioner opposed the renewal, claiming it was already providing complete, efficient, and satisfactory service on the same lines.
  • The PSC granted the renewal, and the petitioner appealed.

Evidence in G.R. No. L-10409

  • The respondent presented evidence showing:
    • Daily trips by merchants to and from Daet for business transactions.
    • Urgent need for transportation in the fishing district of Mercedes to transport products to Daet.
    • Mining operations in Panganiban requiring transportation for laborers and supplies.

Issue:

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Ruling:

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Ratio:

  • The Court held that the conditions for granting or renewing a certificate of public convenience are not limited to the resumption of pre-war operations by a prior operator. Factors such as population growth, economic development, increased commercial and industrial activities, and the need for adequate transportation services must also be considered.
  • The PSC has the discretion to evaluate these factors and determine whether the public convenience and necessity warrant the issuance or renewal of a certificate, even if a prior operator has resumed its services.
  • The emergency certificate's condition allowing the PSC to modify or alter it based on changing circumstances does not imply that the certificate automatically expires upon the resumption of pre-war operations by another operator.


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