Title
Camarines Sur Industry Corp. vs. Buenaflor
Case
G.R. No. L-15490-93
Decision Date
Apr 29, 1961
Dispute over ice plant and cold storage permits; Buenaflor granted priority as Camarines Corporation’s expired corporate status invalidated its claims.
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Case Digest (G.R. No. L-15490-93)

Facts:

  1. Background of the Case:

    • The case involves a dispute between Camarines Sur Industry Corporation (petitioner) and Jaime T. Buenaflor (respondent) over the issuance of certificates of public convenience to operate an ice plant and cold storage service in Sabang, Calabanga, Camarines Sur.
  2. Applications Filed:

    • On June 25, 1957, Buenaflor filed two applications: one for a one-ton ice plant (P.S. Case 107548) and another for a cold storage service (P.S. Case 107549).
    • On October 1, 1957, Camarines Corporation filed its own applications: one for a 5-ton ice plant (P.S. Case 109874) and another for a cold storage service (P.S. Case 109875).
  3. Corporate Status of Camarines Corporation:

    • The corporate life of the old Camarines Corporation expired in November 1953, but it continued to operate illegally.
    • On October 30, 1957, a new corporation, Camarines Sur Industry Corporation, was formed, and it acquired the assets and certificates of the old corporation.
  4. Public Service Commission's Decision:

    • The Commission granted Buenaflor a certificate for a one-ton ice plant and a 5,000 cubic feet cold storage service.
    • It also granted Camarines Corporation a certificate for a 5-ton ice plant but denied its application for a cold storage service.
  5. Appeal to the Supreme Court:

    • Both parties appealed the Commission's decision. The Supreme Court reversed the Commission's decision in favor of Buenaflor, granting him a 5-ton ice plant instead of one ton.

Issue:

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Ruling:

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Ratio:

  1. First in Time, First in Right:

    • The principle that the first applicant should be given priority in the absence of compelling reasons to the contrary.
  2. Corporate Law Compliance:

    • A corporation that has expired cannot continue to operate or apply for new certificates of public convenience. Its operations after expiration are illegal.
  3. No Reward for Illegal Acts:

    • The Court will not reward a corporation for continuing to operate illegally after its corporate existence has expired.
  4. Public Interest:

    • The decision ensures that public services are granted to qualified and legally operating entities, protecting public interest and upholding the rule of law.


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