Case Digest (G.R. No. L-20993) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves the petitioner Rizal Light & Ice Co., Inc., a domestic corporation granted on August 15, 1949, by the Public Service Commission (PSC) a certificate of public convenience and necessity to operate an electric light, heat, and power service in Morong, Rizal. The respondents are the Municipality of Morong, Rizal, the PSC, and Morong Electric Co., Inc. The proceeding began when the PSC issued orders on August 20, 1962, and February 15, 1963, cancelling and revoking the petitioner’s certificate and forfeiting its franchise due to failure to comply with PSC conditions and regulations regarding service voltage and equipment installation. Throughout multiple hearings and inspections from 1956 to 1961, the PSC found the petitioner’s service inadequate and its facilities deficient. Notably, petitioner’s electric plant was destroyed by fire on July 29, 1962. Despite petitioner’s motion for reconsideration citing improvements before the fire and invoking the protection
Case Digest (G.R. No. L-20993) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and case background
- Petitioner Rizal Light & Ice Co., Inc. (Rizal Light) is a domestic corporation operating an electric service in Morong, Rizal.
- Respondents are the Municipality of Morong, Rizal, the Public Service Commission (PSC or Commission), and Morong Electric Co., Inc. (Morong Electric).
- Two cases were consolidated:
- G.R. No. L-20993 – Petition to review orders of PSC cancelling and revoking petitioner’s certificate of public convenience and necessity (CPCN) and forfeiting its franchise.
- G.R. No. L-21221 – Petition to review PSC decision granting CPCN to respondent Morong Electric to operate electric service in Morong.
- Grant and cancellation of petitioner’s certificate
- Rizal Light was granted a CPCN by PSC on August 15, 1949 to operate electric light, heat, and power service in Morong.
- In 1956, PSC ordered Rizal Light to appear and show cause for violating conditions of its CPCN and PSC regulations: failure to raise and maintain service voltage per PSC’s directives and to install kilowattmeters.
- Petitioner failed to appear at the February 18, 1957 hearing; PSC cancelled and revoked its CPCN and forfeited franchise.
- Petitioner moved for reconsideration, explaining failure to appear due to illness of manager Juan D. Francisco; PSC reinstated CPCN after hearing.
- Municipality of Morong opposed reinstatement and filed petition to revoke CPCN and forfeit franchise in 1958 on grounds of unsatisfactory service and non-compliance with PSC requirements.
- Multiple PSC inspections were conducted between 1958 and 1961; petitioner agreed to submit case for decision based on inspection reports without further hearing.
- Petitioner failed to appear at July 5, 1961 hearing; case was submitted for decision after petitioner failed to file its written reply to June 1961 inspection report within prescribed time.
- On July 29, 1962, petitioner’s electric plant was burned.
- PSC decision and aftermath
- On August 20, 1962, PSC found petitioner failed to comply with directives and conditions of CPCN, was incapable of rendering adequate service, and revoked its CPCN and forfeited franchise.
- Petitioner moved for reconsideration arguing improvement before plant burned and protection of investment.
- Meanwhile, Morong Electric obtained a municipal franchise on May 6, 1962 (approved Aug 31, 1962 by Provincial Board of Rizal) and applied for CPCN with PSC on September 10, 1962.
- Petitioner opposed Morong Electric’s application, alleging ruinous competition and prior exclusive right to operate.
- PSC dismissed petitioner’s motion to dismiss Morong Electric’s application on grounds that Morong Electric was a de facto corporation despite lack of SEC certificate at filing.
- PSC granted CPCN to Morong Electric on March 13, 1963, finding absence of electric service in Morong and financial capacity of Morong Electric to provide service.
- Petitioner’s recourse
- Rizal Light filed petitions with the Supreme Court to review:
- PSC’s revocation of its CPCN and franchise (G.R. No. L-20993).
- PSC’s grant of CPCN to Morong Electric (G.R. No. L-21221).
- Petitioner sought preliminary injunctions in both cases, which were denied.
- Petitioner’s allegations before the Supreme Court
- In G.R. No. L-20993, Rizal Light argued PSC:
- Acted without or in excess of jurisdiction in delegating hearing authority to non-lawyer Mr. Pedro S. Talavera.
- Wrongly cancelled its CPCN due to insufficient evidence and denial of opportunity to present evidence.
- Failed to protect its investment.
- Imposed the extreme penalty of revocation instead of lesser penalties.
- In G.R. No. L-21221, Rizal Light argued PSC:
- Erred in denying motion to dismiss Morong Electric’s CPCN application due to lack of legal personality at filing.
- Erred in granting CPCN to financially incapable Morong Electric.
- Made unsupported factual findings.
- Failed to protect petitioner’s investment as prior operator.
Issues:
- In G.R. No. L-20993:
- Did the PSC act without or in excess of jurisdiction by delegating hearing and evidence reception to a non-lawyer division chief?
- Was the cancellation and revocation of petitioner’s CPCN supported by sufficient evidence and was petitioner afforded due process?
- Did the PSC fail to protect petitioner’s investment?
- Was the penalty of revocation of certificate and forfeiture of franchise proper under the circumstances?
- In G.R. No. L-21221:
- Was the denial of petitioner’s motion to dismiss Morong Electric’s CPCN application proper given Morong Electric’s alleged lack of legal personality at filing?
- Did the PSC err in granting CPCN to Morong Electric despite alleged lack of financial capability?
- Are the findings of fact made by the PSC supported by the evidence?
- Did the PSC fail to protect petitioner’s investment as the prior operator?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)