Facts:

On August 24, 1932, the Public Service Commission of the Philippine Islands granted Francisco Javier a certificate of public convenience to operate a taxicab service within the City of Manila and its surrounding areas. Javier indicated his intention to utilize midget motor-propelled vehicles, specifically Austin cars, for this service. However, on August 18, 1932, the Bachrach Motor Company, Inc. filed a complaint in the Court of First Instance of Manila against Javier, seeking the payment of P20,000. In connection with this complaint, a writ of attachment was issued, leading the sheriff of Manila to garnish Javier's interests in the aforementioned certificate. Subsequently, Javier sought permission from the Public Service Commission to substitute Bantam Fords for the Austin cars initially specified in his application. This request was granted by the Commission ex-parte, meaning it was approved without a hearing. In response, the Bachrach Motor Company, Inc. filed a motio...

Facts:

1. Grant of Certificate of Public Convenience:
   On August 24, 1932, the Public Service Commission granted Francisco Javier a certificate of public convenience to operate a taxicab service within Manila and surrounding areas. Javier stated his intention to use midget motor vehicles, specifically Austin cars.

2. Attachment of Javier's Interests:
   On August 18, 1932, the Bachrach Motor Company, Inc. filed a complaint against Javier in the Court of First Instance of Manila for P20,000. A writ of attachment was issued, and the sheriff garnished Javier's interests in the certificate of public convenience.

3. Substitution of Vehicles:
   Javier later filed a motion with the Public Service Commission to substitute Bantam Fords for Austin cars. The Commission granted this motion ex-parte, without a hearing.

4. Intervention by Bachrach Motor Company:
   The Bachrach Motor Company, Inc. filed a motion as an intervenor, seeking reconsideration of the Commission's order. They argued that the attachment of Javier's interests prevented the Commission from modifying the certificate.

5. Denial of Motion:
   The Public Service Commission denied the motion, stating that the modification was in form, not substance. The Bachrach Motor Company, Inc. appealed this decision.

Issue:

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Ruling:

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Ratio:

1. Attachment Does Not Paralyze Commission's Authority:
   The Court held that an attachment does not prevent the Public Service Commission from exercising its regulatory functions over public utilities. Such a doctrine would be contrary to public interest.

2. Modification in Form, Not Substance:
   The substitution of Bantam Fords for Austin cars was a modification in form, not substance. The Commission retained the authority to make such changes without being hindered by the attachment.

3. No Need to Address Other Issues:
   Having resolved the primary issue, the Court found it unnecessary to address other questions raised in the briefs.