Case Digest (G.R. No. L-24165)
Facts:
Juan M. Serrano v. Public Service Commission, G.R. No. L-24165, August 30, 1968, Supreme Court En Banc, Fernando, J., writing for the Court. Petitioner Juan M. Serrano sought a certificate of public convenience from the Public Service Commission (PSC) to operate a fifty-unit taxicab service in the City of Manila and to points in Luzon. His verified application alleged Filipino citizenship, residency, existing public service operations, proposed equipment, rates to be charged, financial capability, and willingness to comply with governing law and PSC regulations.The PSC heard a consolidated set of 99 applications (including petitioner’s) and issued a joint decision of September 7, 1964 listing by name sixty applicants granted certificates but not identifying or giving individualized findings with respect to the unsuccessful applicants. The joint decision contained the blanket statement that applications not listed were "either [dismissed] for lack of interest or failure to prosecute or [denied] for failure to qualify." The record showed Serrano had completed presentation of his evidence and that oppositors presented no rebuttal.
Serrano's application was denied or dismissed in the joint order; he moved for reconsideration which the PSC denied. He then brought this petition for review before the Supreme Court challenging, among other things, the PSC’s failure to state the facts and the law on which it based its action and asserting that the summary disposition vi...(Subscriber-Only)
Issues:
- Does Article VIII, Section 12 of the Constitution (requiring courts of record to state clearly and distinctly the facts and law on which a decision is based) apply to the Public Service Commission?
- Did the PSC's summary disposition—failing to state individualized findings and the reasons for denying or dismissing petitioner’s application—violate petitioner’s right to due process and require annulment and remand?
- Should the Supreme Court decide on the sufficiency of petitioner’s evidence, or is remand to the PSC for a proper...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)