Case Digest (G.R. No. 47065)
Facts:
In Pangasinan Transportation Co., Inc. v. The Public Service Commission (70 Phil. 221, June 26, 1940), the petitioner, engaged for two decades in operating TPU buses across Pangasinan, Tarlac, Nueva Ecija, and Zambales under certificates of public convenience issued by the former Public Utility Commission (Nos. 24948, 30973, 36831, 32014, 53090), applied on August 26, 1939 for authority to operate ten additional Brockway trucks (PSC Case No. 56641). On September 26, 1939, the Public Service Commission granted the equipment increase but, invoking Section 15 of Commonwealth Act No. 146 as amended by Commonwealth Act No. 454, grafted two new conditions into all existing certificates: validity limited to 25 years from the decision’s promulgation and a right for the Commonwealth to acquire the service at cost less reasonable depreciation. The petitioner’s motion for reconsideration, filed October 9 and denied November 14, 1939, prompted its November 20 petition to the Supreme Court fCase Digest (G.R. No. 47065)
Facts:
- Background of the Petitioner
- Pangasinan Transportation Co., Inc. operated TPU buses for over twenty years in Pangasinan, Tarlac, and parts of Nueva Ecija and Zambales under certificates of public convenience Nos. 24948, 30973, 36831, 32014, and 53090 issued by the former Public Utility Commission.
- Certificates authorized fixed routes, schedules, and equipment specified by the Commission.
- Application for Increase of Equipment
- On August 26, 1939, the petitioner filed Case No. 56641 with the Public Service Commission (PSC) to add ten new Brockway trucks, citing compliance with existing certificates and the Eight-Hour Labor Law.
- The PSC granted the application on September 26, 1939, but simultaneously amended the petitioner’s existing certificates to include two new conditions.
- New Conditions Imposed by the PSC
- Certificates would be valid for only twenty-five (25) years from promulgation of the PSC’s decision.
- The Commonwealth of the Philippines (or its instrumentality) could acquire the petitioner’s business at cost of useful equipment less reasonable depreciation.
- Procedural History
- The petitioner moved for reconsideration on October 9, 1939; the PSC denied the motion on November 14, 1939.
- On November 20, 1939, the petitioner filed a petition for certiorari before the Supreme Court, challenging the PSC’s action and the constitutionality and application of Commonwealth Act No. 454.
Issues:
- Constitutional Delegation
- Whether section 1 of Commonwealth Act No. 454 constitutes an unconstitutional, unfettered delegation of legislative power to the PSC.
- Whether the PSC’s authority under that Act is properly limited by legislative standards.
- Applicability to Existing Certificates
- Whether the amendment introduced by Commonwealth Act No. 454 applies to certificates of public convenience issued before June 8, 1939.
- Whether existing franchises/certificates vested perpetual rights unaffected by subsequent legislation.
- Due Process and Administrative Procedure
- Whether the PSC lawfully imposed new conditions without notice or opportunity for the petitioner to be heard.
- Whether the imposition of an arbitrary twenty-five-year term without evidentiary support violates fair-play requirements.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)