Case Digest (G.R. No. L-12019-20)
Facts:
The case involves The Bachrach Motor Co., Inc. (hereinafter referred to as "petitioner") as the petitioner and Ramon J. Guico (hereinafter referred to as "respondent") as the respondent. The events date back to December 6, 1952, when the Public Service Commission (PSC) authorized Guico to operate six round trips between Dagupan City and San Jose, Nueva Ecija, via Sta. Barbara, Urdaneta, and Villasis, as well as six round trips between the same locations via Binalonan, Tayug, and San Quintin. Later, on February 9, 1955, Guico was granted further authority to operate five additional trips from San Fernando, La Union to San Jose, Nueva Ecija, also via Binalonan and Tayug. On August 11, 1955, Guico sought permission to extend routes from Dagupan City and San Jose to Roxas, Isabela, which the petitioner opposed, claiming public convenience did not necessitate such extensions and that Guico lacked financial capability. The opposition raised by Bachrach also pointed
Case Digest (G.R. No. L-12019-20)
Facts:
- In its December 6, 1952 decision (PSC Case No. 64704), the PSC authorized respondent Ramon J. Guico to operate:
- 6 round trips between Dagupan City and San Jose (Nueva Ecija) via Sta. Barbara, Urdaneta, and Villasis (Pangasinan).
- 6 round trips between Dagupan City and San Jose (Nueva Ecija) via Binalonan, Tayug, and San Quintin (Pangasinan).
- On February 9, 1955 (Case No. 62849), the PSC granted respondent authority to operate 5 trips on the line from San Fernando (La Union) to San Jose (Nueva Ecija) via Binalonan and Tayug (Pangasinan).
Background Authorizations by the Public Service Commission (PSC)
- On August 11, 1955, under PSC Case No. 64704, respondent applied for extending:
- One round trip between Dagupan City and San Jose via Binalonan, Tayug, and San Quintin to incorporate the town of Roxas in Isabela.
- One round trip between Dagupan City and San Jose via Sta. Barbara, Urdaneta, and Villasis to include Roxas in Isabela.
- Simultaneously, under Case No. 62849, respondent sought to extend one round trip on the San Fernando (La Union)-San Jose (Nueva Ecija) line via Binalonan and Tayug to Roxas in Isabela.
Application for Extension of Service
- The Pangasinan Transportation Company, Manila Railroad Company, and petitioner The Bachrach Motor Co., Inc.—owners and operators on related routes—filed opposition against these applications.
- Notably, petitioner Bachrach Motor Co., Inc. argued that:
- The existing services rendered from Manila and Nueva Ecija to key provinces (Nueva Vizcaya, Isabela, and Cagayan) were already sufficient.
- Extending the lines would result in duplication, wasteful competition, and would burden a financially incapable respondent.
- A similar application for extensions had previously been denied in PSC Case No. 67250 (subsequently affirmed by the Supreme Court in G.R. No. L-9570).
Opposition by Interested Parties
- The applications were heard jointly, and during the trial, after respondent concluded its evidence, the PSC granted provisional authority on June 7, 1956.
- Following the completion of petitioner’s evidence, the PSC rendered a final decision:
- Overruling petitioner’s opposition.
- Permanently authorizing respondent to operate the extended routes based on the finding that public convenience would be promoted.
Proceedings Before the PSC
- Respondent’s evidence included:
- Testimonies of four regular passengers confirming direct trips from Roxas to Pangasinan and the Ilocos region were frequently full.
- Evidence that such direct service reduced the inconvenience of making transfers at San Jose or other points.
- Supporting documentary and testimonial evidence:
- Testimony from the officer-in-charge of the Narra Settlement Project and the municipal secretary of Mallig indicating continuous passenger movement stemming from migration and recent industrial developments (oil exploration companies).
- A resolution from the Municipal Council of Aurora emphasizing the necessity for direct routes due to local transport needs.
- Petitioner’s evidence was directed mainly at showing no justification for the extension, including checkers’ reports from routes not directly related to Roxas; however, these were found to be less relevant to the specific extended services in dispute.
Evidence and Testimonies on Passenger Traffic
- Petitioner contended that the extension should be denied based on the earlier PSC Case No. 67250 where similar lines were found insufficient in passenger volume.
- The Commission clarified that:
- The earlier case concerned different lines (Dagupan-Ilagan routes) not involving the Roxas-Mallig region.
- The comparative evidence between 1953 (in the earlier case) and the current evidence from 1956 is not analogous given the changed circumstances, particularly due to the establishment of oil exploration companies and increased local traffic.
Comparative Considerations of Previous Decisions
Issue:
- Is there adequate evidence to support a substantial and continuous passenger flow warranting the direct trips?
- Does the evidence demonstrate that without the extension, passengers would suffer inconvenience through transfers, thereby justifying the extension on grounds of public convenience?
Whether the Public Service Commission erred in finding that there was sufficient direct passenger traffic from Dagupan or San Fernando to Roxas (or nearby regions in Isabela) to justify the extension of service.
- Can the evidence from 1956 be considered sufficiently different from that in 1953 to warrant authorizing the extended routes?
- Does the change in economic and social conditions (such as the settlement developments and new industrial activities) provide a sound basis for extending the route?
Whether the Commission correctly reconciled and distinguished the factual differences between the earlier PSC decision (Case No. 67250) and the current applications for extension.
- Whether the application of previous evidentiary findings (from checkers’ reports and witness testimonies) by the PSC is reasonable to support the authorization of the extended routes despite petitioner's contention.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)