G.R. No. 42317 - Manila Electric Co. vs. Public Service Commission

The case involves a petition for certiorari filed by the Manila Electric Company (the petitioner) challenging an order from the Public Service Commission (PSC) (the respondent).
The petition contests the PSC’s directive found in its letter dated July 24, 1934, which ordered the company to desist from enforcing a specific regulation concerning the reconnection of service.

A customer without an outstanding sufficient deposit to guarantee his account for electric service and who was disconnected due to non-payment of bills would not be reconnected.
Before reconnection, the customer must pay all outstanding bills and furnish a deposit equal to the approximate consumption for two months.
The deposit would bear interest at the rate of 6 percent per annum and be refundable at the end of one year, subject to prompt payment of all subsequent electric bills.

This measure was intended to secure future accounts and ensure payment, thereby protecting the utility’s operations.

The regulation was promulgated under subsection (c) of section 16 of Act No. 3108 (Public Service Law), which prohibits public utilities from adopting any regulation or measure that is unjust, unreasonable, unduly preferential, arbitrarily or unjustly discriminatory, or otherwise in violation of law.
The PSC's letter emphasized that public service companies must secure the Commission’s authority before enforcing any such regulation and that the burden of proof is on the company to demonstrate that the measure is just and reasonable.
The jurisprudence also referenced Section 334, No. 31, of the Code of Civil Procedure which establishes the disputable presumption that “the law has been obeyed.”

The petitioner contended that there is no prescribed presumption within Act No. 3108 that public service companies’ measures are unjust, unreasonable, or arbitrary.
It argued that under the principle that “the law has been obeyed,” the burden to prove the justness and reasonableness of the measure should lie with those objecting to it.
The petitioner further questioned the PSC’s authority to require the measure to be submitted for its approval and to demand payment of registration fees prior to the enforcement of the regulation.

Whether there exists a presumption that the measures or rules adopted by public service companies are unjust, unreasonable, or arbitrary in nature.

The issue turns on the interpretation of subsection (c) of section 16 of Act No. 3108.
It also examines whether the burden of proof should be on the petitioner to show the measure is just and reasonable if it is not objected to as unjust, unreasonable, or arbitrary.

Whether the Public Service Commission is authorized to require a public service company to submit its regulation for prior approval and to pay a corresponding registration fee before enforcing such regulation.

This issue involves the scope of the PSC’s regulatory authority as granted by sections 13 and 24(h) of Act No. 3108.
It considers whether the PSC’s imposition of a prior approval process, along with associated fees, is supported by the legislative enactments.