Title
Batangas Laguna Tayabas Bus Co. vs. Cadiao
Case
G.R. No. L-28725
Decision Date
Mar 12, 1968
BLTB contested PSC's jurisdiction and procedural due process in ETBC's unit registration post-lease; SC ruled PSC had authority, BLTB was heard, and dismissed petition for lack of merit.

Case Digest (G.R. No. L-28725)
Expanded Legal Reasoning Model

Facts:

  • Background of the Case
    • Petitioner: Batangas Laguna Tayabas Bus Company, holder of several certificates of public convenience for operating bus services in various southern Luzon provinces extending to Manila.
    • Respondents:
      • Associate Commissioner Josue L. Cadiao of the Public Service Commission (PSC)
      • Land Transportation Commission (LTC)
      • Eastern Tayabas Bus Co., Inc.
    • The dispute involved a lease contract between petitioner and respondent Eastern Tayabas Bus Co., Inc. (entered in 1958 and renewed in 1963), which had ramifications on the operation and registration of units (buses or trucks) needed by the lessee.
  • Chronology of Events and Petition
    • Petition Filed:
      • Petitioner sought a writ of mandamus and contempt coupled with a request for a restraining order.
      • The petition intended to compel the LTC to act on letters dated January 24, February 2, and February 8, 1968.
    • Subject Matter of the Letters:
      • The letters sought the deferment of any action on a request by respondent Eastern Tayabas Bus Co., Inc. for issuing registration plates covering units involved in its lease agreement with the petitioner.
      • The request by Eastern Tayabas was premised on the alleged nullity of an order dated November 2, 1967, issued by Associate Commissioner Cadiao of the PSC.
    • Details of the Contested Order (November 2, 1967):
      • The order granted Eastern Tayabas Bus Co., Inc. permission “to acquire and register units for the operation of the certificates” on the ground that its lease contract with the petitioner would expire on March 6, 1968, although with the proviso that operations would not commence earlier than that date.
      • It also allowed for the petitioner’s contention that under the lease it could terminate the contract pending a 60-day notice, a matter then pending before the regular courts.
  • Jurisdictional and Procedural Allegations Raised by the Petitioner
    • Jurisdictional Challenge:
      • Petitioner argued that the November 2, 1967 order was issued beyond the PSC’s jurisdiction.
      • The contention was based on an earlier decision (August 31, 1966) holding that the PSC lacked jurisdiction to act on matters already pending arbitration between the parties.
      • The earlier decision required resolution in the Court of First Instance of Laguna in Civil Case No. SP-600 before any further action by the PSC.
    • Allegation of Procedural Due Process Violation:
      • Petitioner maintained that the issuance of the November 2, 1967 order was in violation of procedural due process.
      • The allegation centered on the claim that petitioner was not accorded a hearing prior to the issuance of the order.
    • Subsequent Developments:
      • Respondent Eastern Tayabas Bus Co., Inc. filed a motion to dismiss, alleging that the petition was incomplete, inaccurate, and that it concealed material facts (e.g., details of the lease and prior related proceedings).
      • On March 1, 1968, the Court issued a resolution requiring petitioner to serve a copy of its petition to respondent Eastern Tayabas Bus Co., Inc. and allowed until March 4, 1968 for the filing of a motion to dismiss.
      • Both the motion for a restraining order filed by petitioner and the motion to dismiss were scheduled for hearing on March 5, 1968.
      • An amended petition (including pleas for mandamus, contempt, certiorari, prohibition, and injunction with a prayer for a restraining order) was subsequently filed on March 2, 1968, incorporating further allegations of surreptitious actions and capricious conduct on the part of respondent officials.
  • Evidence of Procedural Fairness and Hearings
    • Despite the ex parte issuance of the November 2, 1967 order, petitioner’s earlier petition to set aside and reconsider the order led to a full hearing on January 24, 1968.
    • The respondent’s motion to dismiss further demonstrated that:
      • A Notice of Hearing was issued as early as November 17, 1967, with subsequent hearings held on November 24, 1967, December 7, 1967 (session en banc), and January 10 and 24, 1968.
      • Both parties had the opportunity to present their arguments and relevant evidence during these hearings.
  • Final Developments and Disposition
    • During the oral arguments on March 5, 1968, both the petition and the motion to dismiss were thoroughly argued.
    • The Court found that:
      • The jurisdiction of the PSC was proper as the disputed issue involved the registration and public operation aspects of a public utility.
      • The allegation of procedural due process deficiency was unfounded as the petitioner had been afforded ample opportunity to be heard on a motion for reconsideration.
    • The petition was ultimately dismissed with costs, accompanied by a caution regarding the petitioner’s counsel for omitting material facts which undermined the candor required before the Court.

Issues:

  • Jurisdiction of the Public Service Commission
    • Whether the PSC, through Associate Commissioner Cadiao, had the authority to issue an order concerning the registration and operation of units in a public utility dispute.
    • The extent to which the PSC could determine issues arising from a lease contract between a lessor and lessee, given that a prior decision had limited its jurisdiction over the “private aspect” of such agreements.
  • Procedural Due Process
    • Whether the issuance of the November 2, 1967 order without a prior hearing deprived the petitioner of the fundamental right to due process.
    • Whether the subsequent notice and hearing on January 24, 1968, sufficed to cure any defect in procedural fairness.
  • Completeness and Accuracy of the Presentation of Facts
    • Whether the petitioner’s omission of material facts (such as the history of the lease agreement and prior related proceedings) was deliberate and whether such omissions impacted the adjudication of the matters presented.
    • Whether these omissions contributed to a case that lacked merit on its face.
  • Abuse of Discretion and Unclean Hands
    • Whether respondent Eastern Tayabas Bus Co., Inc.’s motion to dismiss, which argued that petitioner “came to this Court with unclean hands,” was substantiated by the evidence.
    • Whether the conduct of petitioner’s counsel, in allegedly concealing material facts, warranted judicial admonition.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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