Case Digest (G.R. No. L-4821)
Facts:
The case involves Natividad Ariaga as the petitioner and Elpidio Javellana as the respondent. The events leading to this case began with three separate applications filed by Mariano Cacho, Juan Salvador, and Natividad Ariaga with the Public Service Commission (PSC) on March 28, 1950. They sought a certificate of public convenience to install, maintain, and operate a 30-ton ice plant with cold storage services in the City of Iloilo, along with the authority to sell ice throughout the Province of Iloilo. The applications faced opposition from Elpidio Javellana and La Paz Ice Plant and Cold Storage Co., Inc., both of which were existing operators in the area. The PSC heard the applications jointly and granted the petitioners a certificate to operate a 15-ton daily capacity ice plant and a cold storage room of 10,000 cubic feet within the City of Iloilo. Following this decision, Javellana filed a motion for reconsideration on April 25, 1950, while La Paz Ice Plant sought a review...
Case Digest (G.R. No. L-4821)
Facts:
- Applications for Ice Plants: Natividad Ariaga, along with Mariano Cacho and Juan Salvador, filed separate applications with the Public Service Commission (PSC) seeking certificates of public convenience to install, maintain, and operate 30-ton ice plants with cold storage services in Iloilo City. They also requested authority to sell ice in Iloilo City and its surrounding municipalities.
- Opposition: Elpidio Javellana and La Paz Ice Plant and Cold Storage Co., Inc., existing ice plant operators in Iloilo, opposed the applications.
- Joint Hearing and Initial Decision: The PSC conducted a joint hearing and, on March 28, 1950, granted the applicants certificates to operate 15-ton ice plants and cold storage facilities in Iloilo City, with authority to sell ice in the city and province.
- Motion for Reconsideration: Elpidio Javellana filed a motion for reconsideration, arguing there was no ice shortage and that he had the preferential right to provide additional services. La Paz Ice Plant also filed a petition for review with the Supreme Court but later withdrew it.
- Supreme Court Directive: The Supreme Court ordered the PSC to act on Javellana’s motion for reconsideration. The PSC issued split decisions: Commissioner Ocampo upheld the original decision, while Commissioners Prieto and Paredes, Jr. modified it, allowing the ice plants to be established anywhere in Iloilo Province.
- Petitioner’s Investment: Natividad Ariaga had already made significant investments in machinery and infrastructure based on the original PSC decision.
Issue:
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Ruling:
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Ratio:
- Evidence-Based Decision: The Court emphasized that the PSC’s decision must be based on the evidence presented. All evidence in the case supported the necessity of establishing the ice plants in Iloilo City, not elsewhere in the province.
- Investment in Good Faith: Natividad Ariaga had made substantial investments in reliance on the original PSC decision. Modifying the decision to require relocation would be unjust and tantamount to punishing her for acting in good faith.
- Public Necessity and Convenience: The Court found that public necessity and convenience justified the establishment of the ice plants in Iloilo City, especially given the increased population and demand for ice after the war.
- No Basis for Modification: The modification proposed by Commissioners Prieto and Paredes, Jr. lacked evidentiary support and was arbitrary. The Court reaffirmed that modifications to PSC decisions must be grounded in the evidence on record.