Case Summary (G.R. No. 9717)
Petitioner and Respondent
The petitioner, the Manila Electric Company, filed a petition for certiorari against the Public Service Commission, challenging a directive issued by the Commission on July 24, 1934. This directive required the Manila Electric Company to refrain from enforcing a specific regulation regarding reconnection of service to customers who had previously been disconnected for non-payment of electric bills.
Decision and Regulation
The regulation in question stated that customers without a sufficient outstanding deposit to guarantee their electric service would not be reconnected after disconnection until all arrears were paid, and a deposit equivalent to two months’ estimated consumption was made. This deposit would bear interest and could be refunded after one year if bills were paid on time.
Legal Framework
The case draws from the provisions in Act No. 3108, particularly Section 16 subsection (c), which prohibits public utilities from enforcing regulations that are unjust, unreasonable, or discriminatory. The core issue revolves around whether a presumption exists that rules enforced by public utilities are unjust or unreasonable.
Presumption of Compliance
The court examined whether there is a legal presumption that regulations adopted by public service companies are inherently unjust or unreasonable. The court concluded that no such presumption exists within the legal framework of Act No. 3108 or any related provisions. It referenced Section 334 of the Code of Civil Procedure, which provides a disputable presumption that the law is obeyed, implying that the Manila Electric Company was in compliance with said statute.
Burden of Proof
Given the established presumption of compliance, the burden of proof falls on those contesting the regulation to demonstrate its alleged injustice or unreasonableness. As a result, the directive from the Public Service Commission, which required the petitioner to affirmatively prove the reasonableness of its measures, was deemed a violation of procedural law.
Authority of the Public Service Commission
The court then analyzed the authority of the Public Service Commission concerning the requirement for prior approval of utility regulations. While the Commission has supervisory power over public utilities, the Act does not mandate that all regulations be submitted for a
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Case Citation
- Citation: 60 Phil. 658
- G.R. No.: 42317
- Date: September 21, 1934
Parties Involved
- Petitioner: The Manila Electric Company
- Respondent: The Public Service Commission
Background of the Case
- The Manila Electric Company filed a petition for certiorari against the Public Service Commission.
- The petition sought a judgment declaring null and void an order issued by the Public Service Commission on July 24, 1934.
- This order directed the Manila Electric Company to refrain from enforcing a regulation concerning customer deposits and reconnections after disconnection due to non-payment.
Regulation in Question
- The regulation stated:
- A customer without a sufficient deposit to guarantee their electric service account, who was disconnected for non-payment, could not be reconnected until:
- All arrears were paid.
- A new deposit equal to two months' estimated consumption was made.
- The deposit would bear interest at 6% per annum and be refundable after one year if all bills were paid on time.
- A customer without a sufficient deposit to guarantee their electric service account, who was disconnected for non-payment, could not be reconnected until:
Legal Basis for the Commission's Order
- The order was based on Section 16(c) of Act No. 3108 (Public Service Law):
- This section prohibits public utilities from adopting any regulations that are unjust, unreasonable, or discriminatory.
- It also places the burden of proof on public utilities to demonstrate the fairness of their regulations.
Key Issues for Determination
Presumption of Justness in Regulations:
- Whether there exists a presumption that the measures adopted by public se
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