Facts:

• Ruben L. Valero and Estrella L. de Valero applied to the Public Service Commission (PSC) on September 9, 1959, for a certificate of public convenience to operate a 5-ton daily ice plant in Olongapo, Zambales.
• The PSC mandated the Valeros to publish their application in two Manila newspapers and notify specific parties, including Alberto A. Galvez, Leonor Asuncion, and the Municipal Council of Olongapo.
• The Valeros complied with the requirements, and no opposition was raised during the hearing, leading to the PSC granting their application on May 26, 1960, effective immediately but subject to finality after 30 days.
• On June 21, 1960, Diosdado Rodriguez, who operated a 10-ton ice plant in San Marcelino, Zambales, petitioned the PSC to set aside the decision, claiming he was an affected party not notified of the proceedings.
• The Valeros contested Rodriguez's petition, asserting he was not authorized to meet Olongapo's ice demands and that the PSC lacked jurisdiction over the area, which was a U.S. Naval Reservation.
• The PSC ruled on February 12, 1962, that Rodriguez was an affected party and ordered the reopening of the case for him to present his opposition.

Issue:

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Ruling:

• The Supreme Court ruled that the Public Service Commission has the authority to reopen a case to allow an affected party, who was not duly notified, to present opposition.
• The Court upheld the PSC's decision to set aside its earlier ruling and conduct a new hearing, affirming that Rodriguez was indeed an affected party...(Unlock)

Ratio:

• The Court's reasoning was based on the principle of due process, which requires that affected parties have the opportunity to be heard.
• The PSC's decision to reopen the case...continue reading