G.R. No. L-20282 - Halili vs. Daplas

The dispute involves an application by Eusebio Daplas for a certificate of public convenience to operate a bus service.
The proposed service was to cover the route from Amparo Subdivision in Caloocan City to Divisoria (Manila) and vice-versa, employing 20 buses.
Fortunato F. Halili filed an opposition to this application.

Testimony of Daplas himself.
Testimonies of Benjamin Salazar (a resident of Novaliches, Quezon City), Leopoldo Garcia (another resident of Quezon City), and Corona B. Venal (a practicing lawyer and resident of Amparo Subdivision).

Petition from the affected public along the proposed line.
Reports by two official checkers appointed by the Public Service Commission (PSC) indicating that there is inadequate service for the residents of Amparo Subdivision and other commuters.

Many residents in Amparo Subdivision are employees and students whose daily routine involves traveling to and from Manila.
Evidence showed that the oppositor’s buses, while making trips along this line, were often already full upon passing through Amparo Subdivision, leaving passengers with difficulty securing transportation.

Testimonies of Halili’s employees, including Inspector Antonio Santiago and Operation Manager Alfredo dela Cruz, emphasized that the current service along the Ipo-Divisoria line was sufficient to meet the needs of commuters.
An additional witness, Isabel Dikit, testified regarding the seating capacity of the oppositor’s buses which supposedly served the area adequately.

Reports by two checkers employed by the oppositor, which observed that there was no significant public necessity for an additional bus service.

The PSC noted that even the oppositor’s own evidence (e.g., testimony by Inspector Antonio Santiago) pointed out inadequacies in the service provided by Halili’s operation.
Despite oppositor claims, evidence including overloaded buses and complaints from residents supported the presence of a public need for additional service.
On the basis of the evidence, the PSC authorized the applicant to operate at least 12 of the 20 buses applied for, deeming this number sufficient to meet the demands of the traveling public.

The applicant established that he is a Filipino citizen and financially capable of maintaining the proposed service.
Observations from the checkers confirmed difficulties faced by passengers in securing seats, which was used to counter the oppositor’s claim of service adequacy.

Whether there was sufficient public necessity and convenience to warrant the approval of the additional bus service proposed by the applicant.

The central question was whether the existing bus service provided by the oppositor was adequate for the public demand.
Another issue was whether the purported risk of ruinous competition, as claimed by the oppositor, would materialize in case of the additional service being granted.

Whether the mere possibility of reduced earnings for the oppositor constituted a valid ground for opposing the application.
Whether the evidence showed that the oppositor would be deprived of fair profits on the capital invested in his business if the additional service were to be approved.

Whether the PSC’s decision was supported by substantial evidence demonstrating that there was room for additional bus service.
If the trial court should defer to the PSC’s factual findings given the evidence submitted.