Facts:

The case involves two separate appeals from the Public Service Commission (PSC) concerning the applications of Binan Transportation Company (Binan Co.) and Jose Silva, both seeking to operate additional transportation services on the Manila-Lemery route via Cuenca. Binan Co. filed its application on October 10, 1952, seeking a certificate of public convenience to operate an express service with multiple routes, later amending it to focus solely on the Manila-Lemery line with ten round trips. This application faced opposition from Batangas Transportation Company and Laguna-Tayabas Bus Company, who argued that the existing service was sufficient and that granting the application would lead to unnecessary competition and financial instability for the operators.

On the other hand, Jose Silva, operating under United Bus Lines, applied on April 28, 1953, to increase his fleet by adding twenty-five units, including twelve for the Manila-Lemery line. His application was similarly ...

Facts:

Case Background and Parties Involved:
This case involves two separate appeals consolidated into one decision by the Supreme Court. The appeals arose from decisions of the Public Service Commission (PSC) in two cases:

1. Case No. 68776: Binan Transportation Company (Binan Co.) applied for a certificate of public convenience to operate express service between Manila and Lemery via Cuenca, with ten units or round trips.
2. Case No. 72364: Jose Silva, operating as United Bus Lines, applied for an increase in his existing service with 25 additional units on various lines, including twelve on the Manila-Lemery via Cuenca line.

Both applications were opposed by Batangas Transportation Company (Batangas Co.) and Laguna-Tayabas Bus Company (Laguna Bus), which already operated on the same lines. They argued that the existing service was adequate, additional units would lead to ruinous competition, and Binan Co. was financially incapable of maintaining the service.

Procedural History:

• Binan Co. applied for a provisional permit in May 1953, which was granted.
• Silva applied for a provisional permit in December 1953, which was partially granted.
• The PSC granted Binan Co.'s application for ten units and Silva’s application for ten additional units on the Manila-Lemery line.
• Batangas Co. and Laguna Bus appealed these decisions to the Supreme Court.

Evidence Presented:

• Applicants submitted resolutions from municipal councils and provincial boards requesting more transportation services.
• Oppositors presented evidence that Binan Co. was financially unstable, citing unpaid debts, attachments on its vehicles, and a chattel mortgage on its properties.
• Silva had a history of violating his certificate of public convenience, including abandoning authorized lines and making unauthorized trips.

Commission’s Decisions:

• The PSC granted both applications, ruling that public necessity justified the additional units.
• The majority decision dismissed the oppositors' claims, while Associate Commissioner Aspillera dissented, questioning Binan Co.'s financial capacity.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Public Necessity: The Court found that the existing service was sufficient based on actual passenger counts conducted by PSC agents, which showed an average passenger load of 50-60% of capacity. Resolutions from local councils were deemed unreliable as they often reflected isolated complaints or requests from transportation companies.
2. Ruinous Competition: The Court emphasized the dangers of excessive competition, including financial losses, unsafe practices, and eventual bankruptcy of operators, which would ultimately harm the public.
3. Financial Capacity: Binan Co.’s financial instability, evidenced by unpaid debts, attachments on its vehicles, and a chattel mortgage, demonstrated its inability to maintain the service.
4. Violations of Certificate: Silva’s repeated violations of his certificate of public convenience, including abandonment of lines and unauthorized trips, made him unfit to operate additional units.

The Court criticized the PSC for being too liberal in granting certificates and failing to adequately address the financial and operational issues raised by the oppositors.