Title
Globe Wireless Ltd. vs. Public Service Commission
Case
G.R. No. L-27520
Decision Date
Jan 21, 1987
Globe Wireless Ltd. challenged PSC's jurisdiction after being fined for undelivered telegraphic message; SC ruled PSC lacked authority under its limited regulatory scope.
A

Case Digest (G.R. No. L-27520)

Facts:

  • Parties and Background
    • Petitioner: Globe Wireless Ltd., a Philippine corporation engaged in international telecommunication business under a franchise granted by Public Acts Nos. 3495, 3692, and 4150, as amended by Republic Act No. 4630.
    • Respondents: Public Service Commission (PSC), a now-defunct government regulatory agency, and Antonio B. Arnaiz, the private complainant.
  • Events Leading to the Dispute
    • Antonio B. Arnaiz sent a telegraphic message addressed to Maria Diaz, Monte Esquina 30, Madrid, Spain, through the Bureau of Telecommunications telegraph office in Dumaguete City.
    • The message was transmitted to the Bureau of Telecommunications in Manila and then forwarded to petitioner Globe Wireless Ltd. for onward transmission to Madrid.
    • Globe Wireless Ltd. sent the message to American Cable and Radio Corporation in New York, which relayed it to the Empresa Nacional de Telecomunicaciones in Madrid.
    • The latter entity mislaid the message, causing it not to be delivered to the addressee.
  • Complaint and Proceedings Before PSC
    • Private respondent Arnaiz sent an unverified letter-complaint to then Public Service Commissioner Enrique Medina regarding the non-delivery of his message.
    • The complaint was docketed as PSC Case No. 65-39-OC, and petitioner was required to submit an answer.
    • Petitioner challenged the PSC’s jurisdiction over the complaint and denied liability for the non-delivery.
    • After hearing, the PSC found petitioner responsible for the inadequate and unsatisfactory service, violating the Public Service Act.
    • The PSC ordered petitioner to:
      • Pay a fine of Two Hundred Pesos (P200.00) under Section 21 of Commonwealth Act No. 146, as amended.
      • Refund the sum of P19.14 to the remitter for the undelivered message.
    • Petitioner’s motion for reconsideration was denied, prompting the filing of the present petition for certiorari.

Issues:

  • Whether the Public Service Commission had jurisdiction to discipline and impose a fine upon Globe Wireless Ltd. for the alleged non-delivery of the telegraphic message.
  • Whether the PSC’s order imposing the fine and refund was valid under the applicable statutes and franchise terms granted to Globe Wireless Ltd.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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