Title
Pampanga Bus Co., Inc. vs. Mendiola
Case
G.R. No. L-19558
Decision Date
Nov 29, 1963
Petitioner sought new trial due to lost exhibits; Supreme Court denied, citing sufficient respondent evidence and no proof exhibits were disregarded.

Case Digest (G.R. No. L-19558)

Facts:

  • Parties Involved
    • Petitioner: La Mallorca and Pampanga Bus Company, Inc.
    • Respondent: Cirilo D. Mendiola
  • Exhibits Submitted and Their Loss
    • The petitioner submitted Exhibits D, D-1, D-1-a, D-1-b, D-1-c, and D-1-d.
    • These exhibits were observation reports detailing motors vehicles for hire on the Guagua-San Fernando line, including specifics such as plate numbers, passenger loads, and the directions of travel.
    • The exhibits were at one time in the possession of the Public Service Commission (PSC).
    • The loss of these exhibits occurred while they were with the PSC, and it was reported that, due to their loss, they could not be reconstituted.
  • Purpose and Role of the Exhibits
    • The lost exhibits served as evidence to rebut the respondent's evidence.
    • The petitioner relied on these reports, which were observed by its witness, Pineda, to contest the findings presented by the PSC.
  • PSC’s Decision and Basis
    • The PSC, after evaluating the mass of submitted evidence (inclusive of the lost exhibits before their disappearance), rendered a decision on the matter.
    • The decision noted that:
      • There were ten jitneys and six buses operating on the proposed service line.
      • There was an existing daily commuter demand on this line.
      • The number of vehicles then in operation was insufficient to meet the volume of passengers.
      • The petitioner was financially capable to operate and maintain the service applied for.
    • The decision seemingly took into account the existence and content of the lost exhibits, though subsequent evidentiary review suggested that the absence of these exhibits did not significantly affect the determination.
  • Post-Decision Developments
    • In view of the loss and the impossibility of reconstituting the exhibits, the petitioner moved for setting aside the PSC's decision and sought a remand for a new trial.
    • The respondent registered his opposition to the motion.
    • The Commissioner of the Supreme Court acknowledged the loss in a report, which formed part of the basis for the petitioner’s motion.

Issues:

  • Whether the loss of the petitioner’s submitted exhibits constitutes sufficient ground to set aside the PSC’s decision and remand the records for a new trial.
  • Whether the PSC’s decision was substantially affected by the absence of these exhibits given that alternative evidence (such as the testimony of Pineda) remained intact.
  • To what extent should the Supreme Court intervene by re-weighing or substituting the evidentiary findings of the PSC regarding the operation of the motor vehicle service.
  • Whether the existing evidence adequately supports the factual premises and conclusions reached by the PSC despite the loss of some key documents.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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