Title
Raymundo Transportation Co., Inc. vs. Tanchingco
Case
G.R. No. L-7224
Decision Date
May 27, 1955
A transportation company petitions to restrict the number of units operated by a competitor, but the court affirms the decision of the Public Service Commission to grant the competitor a permanent certificate of public convenience without restricting the number of units, based on the principle that the mere possibility of reduced earnings is not enough to prove ruinous competition.
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Case Digest (G.R. No. L-7224)

Facts:

  • The case involves a petition to restrict the number of units operated by the respondent, A. Gergaray Tanchingco.
  • Tanchingco was granted a temporary certificate of public convenience to operate an auto-truck service between Binangonan, Rizal, and Manila, with four units authorized for use.
  • On February 23, 1948, Tanchingco was permitted by the Public Service Commission to withdraw or lay off two of the units without prejudice to their reinstatement in the future.
  • Tanchingco then applied to have the temporary certificate converted into a permanent one, which was opposed by other operators in the territory.
  • Raymundo Transportation Co., Inc., the petitioner in this case, was the only operator that prosecuted its opposition.
  • The Public Service Commission, after conducting a hearing, decided in favor of Tanchingco's application and granted him a certificate of public convenience good for 25 years to operate the trips and units previously authorized under the temporary certificate.

Issue:

  • (Unlock)

Ruling:

  • The court affirms the decision of the Public Service Commission, denying the petitioner's request to restrict Tanchingco's operation to only two units.
  • The court finds that the claim of ruinous competition has not been proven.
  • The Commission determined that there is a need for operating the two units previously withdrawn by Tanchingco, as eleven of the petitioner's authorized units are in storage and not in actual operation.
  • Therefore, the operation of Tanchingco's two laid-off units would only replace part of the service that the petitioner is not providing to the public.
  • The court also notes that while the petitioner claims losses, there is no showing that these losses were caused by ruinous competition or a decrease in business volume due to an increase in the number of competing units.
  • The court emphasizes that the mere possibility of a reduction in earnings is not sufficie...(Unlock)

Ratio:

  • The court's decision is based on the principle that the mere possibility of ...continue reading

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