Case Digest (G.R. No. L-10371)
Facts:
In the case of A. L. Ammen Transportation Co., Inc. vs. Daniel Rayala and Enrique De Leon, the dispute arose from two separate petitions filed by the respondents, who were holders of emergency certificates of public convenience to operate auto-truck services in specific areas of the Philippines. The first petition, G.R. No. L-10371, involved Daniel Rayala, who applied to the Public Service Commission (PSC) for a regular certificate to operate over the Oas (Albay) lines. The petitioner, A. L. Ammen Transportation Co., Inc., a pre-war operator in the same territory, opposed the application, arguing that the conditions justifying the emergency certificate had ceased to exist since they had resumed their pre-war operations with 263 units acquired in 1952. The PSC conducted hearings and ultimately granted Rayala's application, leading to the petitioner’s appeal.
The evidence presented by Rayala indicated a significant demand for transportation services in the area, citing he...
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:
- (Unlock)
Ruling:
- (Unlock)
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.