Title
Philippine Global Communications, Inc. vs. Relova
Case
G.R. No. L-52819
Decision Date
Oct 2, 1980
Philippine Global Communications sought to establish a Cebu branch for international telecom services, facing opposition. Jurisdictional dispute arose over legislative franchise interpretation, resolved by the Supreme Court favoring judicial review over administrative action.

Case Digest (G.R. No. 174773)
Expanded Legal Reasoning Model

Facts:

  • Filing and Application
    • Petitioner Philippine Global Communications, Inc. filed an application with the Board of Telecommunications on May 10, 1976.
    • The application sought authority to establish a branch or station in Cebu City for rendering international telecommunications services from Cebu City to points outside the Philippines where it is licensed to operate.
  • Opposition and Board Decision
    • The application was opposed by the Solicitor General and private respondents.
    • On March 9, 1979, the Board of Communications rendered a decision recognizing the petitioner’s right under its legislative franchise to establish branches or stations anywhere in the Philippines, subject to prior approval.
  • Motion for Reconsideration and Jurisdictional Dispute
    • A joint motion for reconsideration was filed by private respondents (and later opposed by the petitioner) on June 14, 1979.
    • In their opposition, private respondents questioned the jurisdiction of the Board of Communications (now the National Telecommunications Commission) to act on the application.
    • The motion for reconsideration on jurisdiction remained pending before the Commission.
  • Action for Declaratory Judgment
    • On August 27, 1979, private respondents filed an action for declaratory judgment before respondent Judge Benjamin Relova.
    • The action sought to ascertain the scope and coverage of the petitioner’s legislative franchise.
    • The petitioners moved to dismiss the suit on the ground that the issue pertained to the commission’s exclusive authority.
    • The motion to dismiss was denied by respondent Judge Relova on January 15, 1980, on the ground that the basis for dismissal was not indubitable.
  • Proceedings in the Supreme Court
    • Petitioner elevated the matter through a certiorari and prohibition proceeding.
    • On March 6, 1980, the Supreme Court issued a resolution requiring respondents to file an Answer within ten days and issued a Temporary Restraining Order.
    • Subsequently, on April 21, 1980, a joint answer was filed by the respondents, clearly addressing the jurisdictional controversy regarding the petitioner’s legislative franchise and its right to render international versus domestic telecom services.

Issues:

  • Jurisdictional Competence
    • Whether respondent Judge Benjamin Relova had the proper jurisdiction to determine the scope and coverage of the petitioner’s legislative franchise.
    • Whether the question of whether the petitioner may establish a branch or station in Cebu City, given the limitations of its franchise (rendering international services exclusively through a designated “sole gateway” in Manila), falls within the primary jurisdiction of the National Telecommunications Commission.
  • Appropriateness of Judicial Relief
    • Whether the pending administrative motion for reconsideration precludes the judicial resolution of the declaratory relief action.
    • Whether a suit for declaratory relief is the proper remedy or if the issue should be resolved by the administrative agency under the doctrine of primary jurisdiction.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

Analyze Cases Smarter, Faster
Jur helps you analyze cases smarter to comprehend faster—building context before diving into full texts.