G.R. No. L-20699 - Olongapo Jeepney Operators Association vs. Public Service Commission

The case involves an application by Diosdado Bartolo for a certificate of public convenience to operate a transportation public utility service (jeepneys) on the route from Sta. Rita (Olongapo) to Magsaysay Drive (Naval Base gate) in Olongapo, Zambales.
The Public Service Commission (PSC) issued an order dated June 28, 1962, setting a hearing for July 30, 1962, and laid down strict notification requirements for those affected by the application.

Notice of the hearing be published in two newspapers of general circulation.
Individual notices be sent by registered mail to all operators listed as affected, at least ten (10) days before the hearing.
The applicant submit, during the hearing, an affidavit from the person responsible for mailing these notices as proof of compliance.

The list contained 62 names, with the majority (60) being residents of Olongapo, Zambales.
Although the publication in newspapers on July 5, 1962, complied with the publication requirement, the individual mailed notices were posted only on July 25, 1962, from Manila.

Due to the late mailing, recipients in Zambales likely received the notifications only during the first week of August, well after the scheduled hearing date of July 30, 1962.
The registry return cards corroborated that the notices were received only after the intended timeline.
No affidavit was eventually presented to attest to mailing the notices at least ten days in advance, further evidencing the procedural lapse.

The Olongapo Jeepney Operators Association, representing the affected jeepney operators, filed a motion on August 6, 1962, requesting either the reopening of the case or the setting aside of the decision favoring Bartolo.
Their motion argued that:

The failure to comply with the notice requirement deprived them of their day in court.
Granting the certificate would no longer serve public convenience and necessity.

Despite the oppositor’s copy of the motion being stamped as received, the motion did not appear in the official records of PSC Case No. 62-3695, and no action was taken on it.

On July 30, 1962, it is unclear what transpired at the hearing, as the records do not indicate any postponed schedule or proper notification of rescheduling to the affected parties.
On August 20, 1962, Atty. Jesus K. Calderon was designated to receive the applicant’s evidence, but the affected operators were absent, resulting in an order of default being entered against them.
Consequently, on November 16, 1962, a decision was rendered granting Bartolo a certificate to operate 2 jeepneys along the specified route.
The affected jeepney operators only learned of this decision in December 1962 when inquiring at the Motor Vehicles Office, prompting the subsequent petition for review.

Whether the PSC’s failure to comply with its own notification requirements—specifically, the individual notice to affected operators—invalidated the administrative proceedings.
Whether publication in two newspapers alone could satisfy the statutory and procedural requirement for notifying interested parties, particularly when combined with (but not substituting) individual notice.
Whether the affected jeepney operators were deprived of their right to due process (i.e., their day in court) as a result of not receiving timely notice of the hearing.
Whether the entry of default against the operators—in light of the inadequate notification—rendered the decision granting Bartolo the certificate null and void.