Title
Dangwa Transportation Co., Inc. vs. Public Service Commission
Case
G.R. No. L-16899
Decision Date
Oct 29, 1965
PANTRANCO sought to extend its Baguio-Tarlac route to Manila, opposed by Dangwa, citing ruinous competition. PSC approved, citing public convenience; SC upheld, ruling no procedural denial or harm to competitors.

Case Summary (G.R. No. L-16899)

Factual Background

The Respondent was granted authority by the Public Service Commission to operate bus services between Baguio and Tarlac, executing five percent round trips daily. On June 29, 1959, the Respondent sought permission to extend its operations southward to Manila while maintaining existing round-trip operations and stipulating that no passengers would be accepted between Tarlac and Manila. The rationale for this request stemmed from the inconvenience experienced by passengers needing to transfer buses at Tarlac. The Petitioner opposed this extension, asserting that it was already meeting market demand and that the approval could instigate ruinous competition.

Proceedings Before the Public Service Commission

The Public Service Commission conducted hearings on the extension application on various dates, including August 4, 1959, and subsequent hearings in December 1959 and January 1960. The Petitioner filed its own application for more trips between Baguio and Manila shortly after the initial hearing. During the proceedings, the Petitioner sought a postponement of its scheduled appearance without notifying the Respondent, which later led to its absence during the Commission's consideration of the evidence.

Commission's Findings and Decision

The Commission ultimately determined that there existed a need for the extension based on the evidence presented that supported the contention that many passengers required direct service from Baguio to Manila. Evidence indicated that not only were there plenty of passengers making these trips but that the existing Baguio-Tarlac line did not serve them adequately due to the necessity of transferring buses. The decision to permit the extension was based on the finding that it would promote public convenience while affirming that the service would remain express, with no local pickups or drop-offs on the Tarlac-Manila route.

Petitioner's Contentions

In appealing the Commission's decision, the Petitioner first contended that the Commission had overlooked the legal principle that established operators should have preferential consideration over newly emerging competitors. The Petitioner cited prior case law, particularly Batangas Transportation Co. vs. Orlanes, asserting that it set a precedent for protecting established operators from competition by newer entities. However, the court clarified that the Respondent was not an irregular operator but had existing authority for a service that ju

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