G.R. No. L-24165 - Serrano vs. Public Service Commission

Juan M. Serrano, the petitioner, applied for a certificate of public convenience to operate a taxicab service in the City of Manila and its environs, including routes reaching any point in the Island of Luzon open to motor vehicle traffic.
The application was made in response to a Public Service Commission (PSC) decision granting certificates to 60 out of 99 applicants, with the remaining applications being dismissed or denied without individual explanation.
Petitioner asserted that he met all qualifications: he is an adult Filipino citizen, married, and a resident of Quezon City; he has previous experience as a public service bus operator holding several certificates; and he is financially capable of establishing and maintaining the proposed taxicab service using fifty (50) units of bantam closed cars.

The application was heard by Associate Commissioner Gregorio C. Panganiban, where evidence was presented solely by the petitioner regarding his qualifications and financial capacity.
No rebutting evidence was introduced by the oppositors concerning the petitioner's submitted documentation and assertions.
The PSC rendered a decision dismissing or denying the petitioner's application, stating that applications not included in the approved list were “either dismissed for lack of interest or failure to prosecute or denied for failure to qualify,” without a specific individualized explanation for petitioner.

Petitioner argued that the absence of an individualized statement of facts and reasons for the dismissal or denial of his application constituted a violation of his due process rights.
He relied on the constitutional mandate—“no decision shall be rendered by any court of record without expressing therein clearly and distinctly the facts and the law on which it is based”—asserting that this requirement should extend to administrative tribunals when deciding on controversial issues.
A motion for reconsideration filed with the PSC was also denied, prompting the petitioner to file the present petition for review.

The decision under review was issued by the Public Service Commission, an administrative body characterized in previous cases (e.g., Dagdag v. Public Service Commission and Filipino Bus Co. v. Philippine Railway Co.) as not being a court due to its administrative and quasi-judicial functions.
Despite its non-judicial character, the PSC’s actions in dismissing or denying applications without sufficient explanation were challenged on the ground that they failed to meet basic due process requirements as mandated in justiciable cases.

Whether the Public Service Commission, although an administrative body and not a court of record, is still required to provide a detailed, individualized statement of facts and reasons in its decisions, particularly when dismissing or denying an application for a certificate of public convenience.
Whether the summary manner in which the PSC dismissed or denied the petitioner's application violated his due process rights, given that he was not informed of the specific reasons or the evidence supporting the decision.
Whether the proper exercise of the PSC’s quasi-judicial powers mandates a reevaluation of the evidence and a more detailed elucidation of the factual basis for the decision, thereby necessitating remand for reconsideration on the merits.