Title
Halili vs. Daplas
Case
G.R. No. L-20282
Decision Date
May 19, 1965
Eusebio Daplas applied to operate a bus service on a route served by Fortunato Halili, who opposed, claiming adequacy. PSC found Halili’s service insufficient, approving Daplas’ application. SC upheld PSC, citing public necessity and lack of proof of ruinous competition.

Case Summary (G.R. No. L-20282)

Background and Initial Proceedings

Halili filed an opposition to Daplas's application, asserting that the existing bus services he operated were sufficient to meet the public's transportation needs. Both parties presented testimonial and documentary evidence to support their positions. The PSC, after careful consideration, authorized Daplas to operate at least 12 of the 20 buses requested, qualifying the decision with certain conditions.

Evidence Presented

Daplas's evidence illustrated that Amparo Subdivision has a considerable population, notably composed of employees working in Manila and students attending educational institutions in the city. This demographic necessitated additional transportation options, as Halili's service was reportedly inadequate; witnesses testified that Halili's buses were frequently full, resulting in unmet demand for transportation in the area. Halili, in contrast, contended that his current service was sufficient and submitted reports from checkers indicating a lack of necessity for additional services.

Public Service Commission's Findings

Upon evaluating the evidence, the PSC concluded that there was indeed a need for increased bus service on the route in question. Notably, testimonies from Halili's own inspector indicated that Halili operated only three buses making limited trips, which could not adequately serve the population of Amparo Subdivision. The PSC observed that Halili's operations were insufficient, corroborated by testimonies about the full capacities of his buses impacting residents' ability to secure transport.

Conclusion of the Public Service Commission

The PSC determined that Daplas's application should be granted based on substantial evidence supporting public necessity for additional bus services. As Halili could not show any substantial evidence of ruinous competition that would potentially harm his business interests, the Commission’s findings were upheld. The findings of fact made by the PSC, supported by adequate evidence, were deemed conclusive.

Appeal and Court Determination

Halili's appeal against the PSC's decision was addressed, and the court affirmed the Commission's ruling. It emphasized tha

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