Facts:

The case involves the Philippine Shipowners' Association as the petitioner and the Public Utility Commission as the respondent. The events leading to the case unfolded in 1926 when the petitioner filed a petition to prohibit the revenue cutters operated by the Bureau of Commerce and Industry from transporting freight and passengers on routes already served by privately-owned vessels, specifically the San Pedro, Pilar, Gravina, and Midget. The petitioner argued that these private vessels provided adequate and convenient service, with no complaints from the public regarding their operations. The petitioner further claimed that the revenue cutters constituted unfair competition, which could lead to the withdrawal of private vessels from service, ultimately harming both the vessel owners and the public.

In response, the Bureau, represented by the Attorney-General, denied the allegations, asserting that the private vessels were providing inadequate service. They claimed that...

Facts:

1. Parties Involved:

   • Petitioner: Philippine Shipowners' Association.
   • Respondent: The Public Utility Commission.

2. Subject Matter:

   • The petitioner sought to prohibit the revenue cutters of the Bureau of Commerce and Industry from carrying freight and passengers on routes served by private vessels (San Pedro, Pilar, Gravina, and Midget).
   • The petitioner claimed that these private vessels provided adequate and convenient service for traffic between Paragua Island and the rest of the Archipelago.

3. Petitioner's Allegations:

   • The revenue cutters of the Bureau constituted unfair competition, which would eventually lead to the withdrawal of private vessels, causing financial loss to their owners and the public.

4. Respondent's Defense:

   • The private vessels provided deficient, inadequate, and insufficient service.
   • They often refused to carry passengers and freight, lacked fixed itineraries, and had insufficient space and accommodations.
   • The Bureau received numerous complaints about the poor service of private vessels and argued that the revenue cutters were necessary to address these deficiencies.

5. Procedural History:

   • The Acting Public Utility Commissioner dismissed the petitioner's claim.
   • The petitioner filed a motion for a new trial and reconsideration, which was denied.
   • The petitioner appealed, assigning two errors:
     (a) The Commission failed to declare the operation of government revenue cutters as unfair competition.
     (b) The Commission rendered a decision without sufficient evidence.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Unfair Competition:

   • For unfair competition to be established, there must be clear evidence that the government's actions directly harm private entities without justification. In this case, the government's revenue cutters were operating to address deficiencies in private services, not to unfairly compete.

2. Sufficiency of Evidence:

   • Administrative bodies like the Public Utility Commission are not strictly bound by the technical rules of evidence. They may consider documents and testimony that may not be admissible in a court of law, provided they are relevant and reliable.

3. Judicial Review:

   • Courts will not interfere with administrative decisions unless there is a clear lack of evidence to support them. The burden is on the petitioner to demonstrate such a lack, which was not met in this case.