Case Digest (G.R. No. L-26132)
Facts:
The case involves Agapito Cabudil and Juan Reyes as petitioners-vendors, and Arsenio Ramirez as petitioner-vendee, against Hon. Gregorio C. Panganiban, Associate Commissioner of the Public Service Commission, as the respondent. The events leading to the case began on August 25, 1959, when Cabudil and Reyes allegedly sold a franchise to Ramirez for the operation of five jitneys on the Novaliches-Blumentritt line. However, the Public Service Commission (PSC) refused to issue the necessary stickers for Ramirez to operate these jitneys, prompting the petitioners to file a petition on November 23, 1965, seeking approval for the sale and the issuance of stickers.
During the hearing on February 23, 1966, it was revealed that the PSC's records for Case No. 43277, which supposedly granted the franchise to Cabudil and Reyes, could not be located. The docket book indicated that the petitioners had only been granted a franchise for different lines on April 16, 1963, and there was ...
Case Digest (G.R. No. L-26132)
Facts:
1. Filing of the Petition:
- On November 23, 1965, petitioners Agapito Cabudil, Juan Reyes (vendors), and Arsenio Ramirez (vendee) filed a petition with the Public Service Commission (PSC). They sought approval for the transfer of a certificate of public convenience for a five-unit franchise on the Novaliches-Blumentritt line, which they claimed was sold by Cabudil and Reyes to Ramirez on August 25, 1959. They also requested the issuance of operating stickers for Ramirez.
2. Alleged Franchise and Provisional Authority:
- Petitioners claimed that Cabudil and Reyes held a franchise under PSC Case No. 43277 for the Novaliches-Blumentritt line, which was allegedly sold to Ramirez. They further alleged that Ramirez was granted provisional authority on August 26, 1959, under PSC Case No. 127065, to operate five jitneys on the line.
3. PSC Records and Findings:
- During the hearing on February 23, 1966, it was discovered that the PSC records for Case No. 43277 could not be located. However, the docket book revealed that Cabudil and Reyes were granted a franchise on April 16, 1963, to operate eight jitneys on entirely different lines (Duhat, Bocoue-Quiapo, and Frisco-Piers), not the Novaliches-Blumentritt line.
- The PSC also found no record of the alleged provisional authority granted to Ramirez under Case No. 127065.
- Additionally, the records showed that Cabudil and Reyes had already sold their franchise under Case No. 43277 to a third party, Mario Pulongbarit, on July 5, 1961, which was approved by the PSC on July 19, 1963, in Case No. 61-4664. Pulongbarit later disposed of some units under Case No. 62-4360 on July 23, 1962.
4. Denial of the Petition:
- On April 20, 1966, Associate Commissioner Gregorio C. Panganiban denied the petition, stating that the Novaliches-Blumentritt line claimed by petitioners did not exist in the PSC records. The actual franchise held by Cabudil and Reyes had already been sold to a third party, leaving nothing to be sold to Ramirez.
Issue:
- Whether the Public Service Commission erred in denying the petition for approval of the sale and transfer of the franchise to Ramirez.
- Whether petitioners were denied due process in the proceedings before the PSC.
- Whether the official records of the PSC should prevail over the undocumented claims of the petitioners.
Ruling:
The Supreme Court rejected petitioners' appeal and affirmed the PSC's order. The Court held that the official records of the PSC must prevail over the bare and undocumented claims of the petitioners. The Court found no error in the PSC's decision to deny the petition, as the franchise for the Novaliches-Blumentritt line did not exist, and the actual franchise held by Cabudil and Reyes had already been sold to a third party.
Ratio:
Precedence of Official Records:
- The Court emphasized that the official records of the PSC are conclusive and must prevail over the unsubstantiated claims of the petitioners. In this case, the PSC records clearly showed that the Novaliches-Blumentritt line did not exist, and the franchise held by Cabudil and Reyes had already been sold to a third party.
Lack of Due Process:
- The Court rejected petitioners' claim of denial of due process, noting that they had ample opportunity to present their evidence during the hearing. The hearing was conducted fairly, and petitioners were represented by counsel. The failure to present any documentary evidence to support their claims was solely their own doing.
Negligence of Petitioners:
- The Court pointed out that petitioners had six years to verify the status of the franchise and seek approval for the sale but failed to do so. Their inaction and failure to present any supporting documents further weakened their case.
Expiration of Provisional Authority:
- Even assuming that a provisional authority was granted to Ramirez, such authority would have expired after six months. The claim that Ramirez had been operating legally since 1959 was therefore invalid.
Conclusion:
- The Court concluded that there was no basis for petitioners' claims, and the PSC's decision to deny the petition was correct. The order appealed from was affirmed, with treble costs imposed on the petitioners.