Title
Philippine Shipowners' Association vs. Public Utility Commission
Case
G.R. No. 24638
Decision Date
Feb 24, 1926
The Supreme Court denies the Philippine Shipowners' Association's petition against government revenue cutters carrying freight and passengers, citing insufficient evidence of unfair competition.
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Case Digest (G.R. No. 24638)

Facts:

  • The Philippine Shipowners' Association (petitioner) filed a petition against the Public Utility Commission (respondent) in 1926.
  • The petitioner sought to prohibit revenue cutters operated by the Bureau of Commerce and Industry from competing with privately-owned vessels on specific routes.
  • The petitioner argued that private vessels provided adequate service without public complaints.
  • The petitioner claimed that revenue cutters represented unfair competition, risking the withdrawal of private vessels and harming both owners and the public.
  • The Bureau, represented by the Attorney-General, countered that private vessels offered inadequate service, often failing to carry passengers and freight, lacking fixed schedules, and having insufficient accommodations.
  • The Bureau claimed to have received numerous complaints about private vessel services, justifying the need for government-operated revenue cutters.
  • After a hearing, the Acting Public Utility Commissioner dismissed the petition.
  • The petitioner’s motion for a new trial and reconsideration was denied, leading to a review of the Commission's decision.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court denied the petition, finding no merit in the claims of the Philippine Shipowners' Association.
  • The Court upheld the Public Utility Commission's decision, affirming that the operation of revenue cutters ...(Unlock)

Ratio:

  • The Court reasoned that the petitioner did not prove that government-operated revenue cutters engaged in unfair competition.
  • Unlike the National Coal Co. vs. Public Utility Commission case, where government vessels charged significantly lower rates, no similar circumstances existed here.
  • The evidence presented did not substantiate claims of unfair compe...continue reading

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