G.R. No. 164940 - Varorient Shipping Co., Inc. vs. National Labor Relations Commission

On March 17, 1989 at 9:00 AM, Dr. Jimena Alegre, through RCPI’s Taft Ave., Manila station, sent two rush telegrams bearing the identical text “MANONG POLING DIED INTERMENT TUESDAY” to relatives in Valencia, Bohol and Espiritu, Ilocos Norte.
The telegram to Valencia arrived on March 21, 1989 (three-day delay) and the one to Ilocos Norte on March 20, 1989 (two-day delay).
Juan A. Alegre filed a letter-complaint with the National Telecommunications Commission (NTC) for deficient service and sought punitive sanctions against RCPI.

NTC directed RCPI to answer and set the initial hearing on May 2, 1989; after two postponements, RCPI moved to dismiss for lack of real party in interest, absence of NTC jurisdiction, and violation of due process, and also sought deferment of hearings pending resolution of its motion.
On June 15, 1989 NTC proceeded with the hearing, received evidence for private respondent, and on October 3, 1989 denied RCPI’s motion to dismiss, treating it as an answer or to be passed upon after the merits.

Hearings resumed without RCPI’s appearance; on November 27, 1989 NTC found RCPI administratively liable under Section 19(a) of C.A. 146 and imposed a total fine of P1,000 (P600 for the Bohol telegram and P400 for the Ilocos Norte telegram), payable within 30 days.
RCPI’s motion for reconsideration was denied, leading to this petition for review before the Supreme Court, invoking lack of jurisdiction under C.A. 146 Sec. 19(a) and reliance on prior decisions limiting the PSC/NTC to rate-fixing powers.

Whether the NTC has jurisdiction under Commonwealth Act No. 146, as amended, to impose administrative fines on a telegraph company for delivering telegrams late.
Whether Executive Order No. 546 (E.O. 546)—which gives NTC supervisory and regulatory functions—implicitly grants authority to impose fines for inadequate telecommunication service.
Whether subsequent legislation or E.O. 546 effectively overruled earlier jurisprudence (RCPI vs. Francisco Santiago; Globe Wireless vs. PSC) that confined PSC/NTC powers to rate fixing and certificate compliance only.