Title
Compania General de Tabacos de Filipinas vs. Board of Public Utility Commissioners
Case
G.R. No. 11216
Decision Date
Mar 6, 1916
A foreign corporation challenged the Board of Public Utility Commissioners' order for detailed annual reports, arguing unconstitutional delegation of legislative power. The Supreme Court ruled in favor, deeming Section 16(e) of Act No. 2307 unconstitutional due to lack of legislative standards.
A

Case Digest (G.R. No. 11216)

Facts:

  • Parties and Subject Matter
    • Petitioner: Compania General de Tabacos de Filipinas, a foreign corporation organized under Spanish law engaged in water transportation of passengers and merchandise within the Philippine Islands.
    • Respondent: Board of Public Utility Commissioners (BPUC) of the Philippine Islands.
    • Nature of Case: Petition for review of an order issued by BPUC requiring the petitioner to file detailed annual reports of its finances and operations regarding its vessels operated as a common carrier.
  • Procedural History
    • On or about June 7, 1915, BPUC issued an order to show cause to the petitioner why it should not be required to file detailed reports of finances and operations in a prescribed form (model report appended).
    • After a hearing, BPUC ordered the petitioner to annually submit such detailed reports on or before March 1 of each year.
    • Petitioner opposed, denying the Board’s authority under Act No. 2307 and claiming that the statute constituted an unconstitutional delegation of legislative power. Petitioner also complained that the reporting requirements were overly burdensome and unnecessarily detailed.
    • The petition was brought before the Supreme Court pursuant to section 37 of Act No. 2307.
  • Statutory Basis
    • Section 16(e) of Act No. 2307 authorizes the Board “after hearing” and upon notice, to order every public utility to furnish annually a “detailed report of finances and operations,” in such form and containing such matters as the Board may prescribe by order.
    • The provision is general and broad, leaving specifics of the report entirely to the Board's discretion.

Issues:

  • Whether Section 16(e) of Act No. 2307 constitutes an unconstitutional delegation of legislative power to the Board of Public Utility Commissioners.
  • Whether the Board has the authority to require the petitioner to file detailed annual reports in the form prescribed by the Board.
  • Whether the reporting requirements imposed by the Board are unduly burdensome or unreasonable under the law.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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