Facts:

In the case entitled Angat-Manila Transportation Co., Inc. v. Victoria Vda. de Tengco, decided on May 26, 1954, by the Supreme Court of the Philippines (G.R. No. L-5906), the respondent, Victoria Vda. de Tengco, filed an application with the Public Service Commission for a certificate of public convenience to operate six passenger and freight buses between San Miguel, Bulacan, and Manila. The application faced opposition from several entities, including Angat-Manila Transportation Co., Inc. (the petitioner), Pampanga Bus Co., and several other operators, who argued that their existing bus services adequately met the public's transportation needs in the area. While the opposition presented minimal evidence, the respondent provided substantial evidence indicating that residents of San Miguel experienced significant difficulty securing bus transport to Manila, often finding existing buses overburdened. The Public Service Commission found that the population of San Miguel, appro

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Facts:

Background of the Case

• Victoria Vda. de Tengco filed an application before the Public Service Commission seeking a certificate of public convenience to operate six passenger and freight buses between San Miguel, Bulacan, and Manila.
• The application was opposed by several parties, namely Pampanga Bus Co., Nicolas Javier, Bachrach Motor Co., Gaudencio Nicolas, Enrique de Leon, Angat-Manila Transportation Co., Inc. (petitioner), and Valentin Fernando.
• Despite the number of oppositors, only two actually presented evidence to support their opposition.

Evidence and Testimonies Presented

• The respondent’s evidence focused on the public need for frequent and reliable bus service for San Miguel’s residents:
• The town of San Miguel has a population of about 35,000 and boasts two markets, three market days, as well as approximately 200 merchants who regularly travel to Manila.
• Numerous students, employees, and laborers rely on regular transit between San Miguel and Manila.
• The evidence stressed that although buses already passing through San Miguel exist, they are typically so heavily loaded that they barely accommodate additional passengers.
• It was argued that a dedicated bus service directly from San Miguel to Manila would ensure that the residents receive reliable transportation.
• The oppositors’ evidence primarily depended on:
• Testimonies of Agents Marabut and Carpio concerning the passenger loads at San Miguel over a nine-day period.
• Reports that provided figures on the number of passengers at San Miguel, though without clarifying how many could actually board the buses or their return capacity from Manila.

Decision by the Public Service Commission

• Based on the evidence, the Public Service Commission granted the certificate of public convenience:
• It found a demonstrated need for an exclusive bus service from Manila to San Miguel, Bulacan.
• The commission believed that such a service would be more convenient and beneficial to the public than the existing bus services that merely pass through San Miguel.
• The new service would ensure that the people of San Miguel have bus facilities in their own town, meeting their transportation needs adequately.

Petition for Review

• Angat-Manila Transportation Co., Inc. (the petitioner) appealed the decision of the Public Service Commission.
• The petitioner argued that granting the certificate would result in destructive competition with the existing bus operators on the Manila-Baliwag route and other routes passing through San Miguel.

Issue:

Sufficiency of the Evidence

• Whether the evidence presented to the Public Service Commission substantiated the need for a dedicated bus service between San Miguel and Manila.
• Whether the commission’s findings were supported by a balance of evidence, particularly given the limited active opposition from the oppositors.

Competitive Impact

• Whether the authorization of the six additional buses would create destructive competition against existing bus operators in the affected areas, particularly between Baliwag and Manila, and other operators whose routes pass through San Miguel.
• Whether the petitioner’s contention that existing operators who already serve or pass through San Miguel should have priority was adequately considered.

Judicial Review of Administrative Findings

• Whether the judicial court should substitute its judgment for that of the Public Service Commission on questions of fact and evidentiary assessment.
• Whether the administrative decision was clearly against evidentiary support, warranting interference by the court.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)