Title
Ariaga vs. Javellana
Case
G.R. No. L-4821
Decision Date
Dec 17, 1952
The Supreme Court reversed the Public Service Commission's modification, upholding the original approval for ice plant installations in Iloilo due to confirmed past decisions and significant investments without evidence of demand in the province.
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Case Digest (G.R. No. L-4821)

Facts:

  • Natividad Ariaga (petitioner) and Elpidio Javellana (respondent) are involved in a dispute regarding ice plant operations.
  • On March 28, 1950, Mariano Cacho, Juan Salvador, and Natividad Ariaga applied to the Public Service Commission (PSC) for a certificate of public convenience to operate a 30-ton ice plant and cold storage in Iloilo City.
  • Elpidio Javellana and La Paz Ice Plant opposed the applications, as they were existing operators in the area.
  • The PSC granted a certificate for a 15-ton daily capacity ice plant and a cold storage room of 10,000 cubic feet in Iloilo City.
  • Javellana filed a motion for reconsideration on April 25, 1950, while La Paz Ice Plant sought a review from the Supreme Court.
  • The PSC delayed action on Javellana's motion until the Supreme Court resolved La Paz's petition.
  • After La Paz withdrew its appeal, Javellana urged the PSC to reconsider, which was initially denied.
  • The Supreme Court ordered the PSC to act on Javellana's motion, leading to modifications allowing ice plants to be established anywhere in Iloilo Province.
  • Ariaga filed a motion for reconsideration against these modifications, which was denied by a split vote of the PSC, prompting her to seek a review.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court ruled in favor of Natividad Ariaga, nullifying the orders of Commissioners Prieto and Paredes.
  • The Court upheld the PSC's original decis...(Unlock)

Ratio:

  • The Court emphasized that modifications to PSC decisions must be supported by evidence from hearings.
  • The evidence indicated a necessity for the ice plants to be located within Iloilo City, with no substantial evidence from oppositors to suggest alternative locations would suffice.
  • The modification by Commissio...continue reading

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