Title
Generoso Villanueva Transportation Company, Incorporated vs. Locsin
Case
G.R. No. L-31460
Decision Date
Jul 25, 1975
The court dismissed the taxi operator's opposition to a certificate of public convenience, ruling the operator lacked legal interest in the case.
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Case Digest (G.R. No. L-31460)

Facts:

  • The case involves Generoso Villanueva Transportation Co., Inc. (petitioner) and Leticia B. Locsin, along with the Public Service Commission (respondents).
  • Leticia B. Locsin applied for a certificate of public convenience to operate a taxi service in Silay City, located about 15 kilometers from Bacolod City, where the petitioner was based.
  • The Public Service Commission dismissed the petitioner's opposition to Locsin's application, stating that the opposition was invalid since the proposed area was too far from the petitioner's base.
  • The Commission noted that an existing operator's right to oppose applications should not extend to areas where they do not operate, especially when there is no legal operator in the proposed area.
  • The petitioner contested the Commission's order, claiming it was issued without jurisdiction or with grave abuse of discretion.
  • Locsin filed a motion to dismiss the petition, arguing that the petitioner had ceased operations since April 3, 1974, and thus lacked legal interest in opposing the application.
  • The petitioner admitted to ceasing its taxi operations due to a labor dispute.
  • The court found the case moot and academic due to the petitioner's lack of legal interest.

Issue:

  • (Unlock)

Ruling:

  • The Public Service Commission had jurisdiction to dismiss the opposition of the petitioner.
  • The opposition of the petitioner was not valid due to its cessation of operations.
  • The petition for certiorari and prohibition was dismissed for being moot and academic.

Ratio:

  • The Supreme Court ruled that the Public Service Commission acted within its jurisdiction when dismissing the opposition of Generoso Villanueva Transportation Co.
  • The Commission's decision was based on the distance of the petitioner from the proposed area of operation, rendering the opposition too remote to be legally considered.
  • The Court emphasized that the right to oppose applications should be limited to areas where operators actively operate.
  • The petitioner admitted to ceasing taxi operations since April 3, 1974, which eliminated any legal interest in contesting Locsin's application.
  • This admission rendered the case moot and academic, as there was no valid basis for the petitioner to challenge the Commission's order.
  • Consequently, the petition was dismissed, and the previously issued preliminary injunction was lifted, as it no longer had any force or effect.

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