Facts:

On April 23, 1962, Gavino Camunayan submitted an application to the Public Service Commission to operate a bus service transporting passengers and freight between Cordon (Isabela) and Buguey (Cagayan) using 15 auto-trucks. Bachrach Transportation Co., Inc., a domestic corporation engaged in operating a fleet of buses for passenger and freight transportation in various provinces, vehemently opposed Camunayan’s application. Following appropriate administrative proceedings, the Commission issued a ruling on March 5, 1963, sanctioning Camunayan’s request, finding sufficient evidence to establish a public demand for the proposed service on the specified line. The judgment led to the issuance of a certificate of public convenience for the operation of the auto-truck service between Ilagan (Isabela) and Buguey (Cagayan) with the specified number of units. Bachrach Transportation Co., Inc. responded by filing a petition for review, challenging the Commission’s decision on grounds includ

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Facts:

Background of the Case

• On April 23, 1962, Gavino Camunayan filed an application with the Public Service Commission (PSC) for authority to operate a bus and freight service on the route from Cordon (Isabela) to Buguey (Cagayan) using 15 auto-trucks.
• Bachrach Transportation Co., Inc., a domestic corporation engaged in operating bus services between Manila and various provinces (including Nueva Ecija, Nueva Vizcaya, Isabela, and Cagayan), objected to Camunayan’s application.

Proceedings before the Public Service Commission

• After the filing and subsequent proceedings, the PSC rendered judgment on March 5, 1963.
• The Commission directed that a certificate of public convenience be issued to Camunayan authorizing him to operate a PUB auto-truck service on the route from Ilagan (Isabela) to Buguey (Cagayan), via Tuguegarao and Aparri, using 15 auto-truck units.
• In the PSC’s decision, it was attested that the evidence submitted by Camunayan demonstrated a public need for the proposed service and that the opposition of Bachrach lacked sufficient proof regarding the alleged negligible passenger load and claimed losses.

Evidence and Testimonies

• The Commission noted that Camunayan had adduced ample evidence of public need, including comparisons with the longstanding operation of Rural Transit in the Cagayan Valley.
• It observed that the oppositor’s proof was diminished by reliance on testimonies from its own employees, whose credibility was questioned due to their special relationship with the company.
• In contrast, the applicant’s witnesses, which included:

- Ricardo Paguirigan, Mayor of Ilagan, - Cesar N. Comin, Chief of Police, - Severino Torres, an agricultural machinery salesman from GAMI covering the Cagayan Valley, and - Jerundio Tarobal, an old resident and farmer in Ilagan, were deemed credible and impartial.

Dispute Regarding the Service Route

• Bachrach Transportation Co. argued that the Commission erred by effectively granting a different line than what was originally applied for, contending that a longer route was approved.
• It was clarified that the original line applied for was from Cordon (Isabela) to Buguey (Cagayan), which was later shortened to Ilagan (Isabela) to Buguey (Cagayan).
• Additionally, although the approved route was via Tuguegarao and Aparri (rather than via Dugo Junction as mentioned in open court), such variation was held to be inconsequential since the application did not specify the exact route details beyond a direct connection between the two points.

Petition for Review by Bachrach Transportation Co., Inc.

• Bachrach Transportation Co. petitioned for review on the grounds that the Commission had erred in granting the certificate by:

- Failing to properly scrutinize the credibility of opposing witnesses, and - Wrongly concluding that public convenience was appropriately served by the service.

Issue:

Whether the PSC committed an error in granting the certificate of public convenience to Camunayan despite the opposition by Bachrach Transportation Co., Inc.

• Did the evidence presented by the applicant sufficiently prove a public need for the service?
• Was the weight given to the testimonies of Camunayan’s witnesses justified and appropriate?

Whether the PSC’s findings were supported by substantial evidence, such that the administrative body’s conclusions are entitled to deference in the absence of grave abuse of discretion.

• Was there any grave abuse of discretion by the PSC in its factual findings?
• Did the Commission overlook or improperly discount the testimonies of the petitioner’s witnesses?

• Whether the slight change in the route—from the original application’s Cordon (Isabela) to Buguey (Cagayan) to the approved route of Ilagan (Isabela) to Buguey (Cagayan) via Tuguegarao and Aparri—affects the validity of the Commission’s decision.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)