Case Summary (G.R. No. L-60548)
Antecedent Facts
On May 10, 1976, PGCI filed an application with the Board of Communications (now the National Telecommunications Commission) to establish a branch station in Cebu City to provide international telecommunication services. This application faced opposition from the private respondents. In the interim, the Board issued Memorandum Circular No. 77-13, designating Metropolitan Manila as the sole gateway for communications in the Philippines. Eventually, PGCI received provisional authority on January 16, 1979, and final authority on May 24, 1979, to establish a station in Cebu City. However, a petition for declaratory judgment was subsequently filed by the private respondents regarding the interpretation of PGCI's franchise.
Legal Issues
The primary legal issues raised by PGCI involved its authority under Republic Act No. 4617 to establish stations outside of Metropolitan Manila and whether such operations would be classified as "domestic service" under its legislative franchise. PGCI contended that the lower court's decision declaring it without authority contradicted its legislative rights.
Court's Analysis of Legislative Franchise
The lower court concluded that the term "any" in Section 1 of PGCI's legislative franchise implied limited operational capacity within the Philippines, which the Supreme Court challenged. The higher court emphasized that legislative intent must be derived from the statute in its entirety, noting that other sections indeed support the establishment of additional stations for international communications, contrary to the lower court’s interpretation.
Contemporaneous Construction
The Supreme Court reiterated the principle that the contemporaneous interpretation of a statute by executive officers is entitled to great respect. It highlighted that the Board of Communications, in its 1979 decision, had correctly interpreted PGCI's legislative franchise, allowing it to establish branch stations in the country for international operations, in line with the established government policy.
Final Decision
Ultimately, the Supreme Court reversed the lower court's decision and affirmed PGCI's authority to establish and operate additional branches within the Philippines apart from its principal station in Makati. The court underscored that this authority must align with both PGCI's franchise and prevailing regulatory guidelines, specifically Memorandu
...continue readingCase Syllabus (G.R. No. L-60548)
Case Citation
- 229 Phil. 388 EN BANC
- G.R. No. 60548
- Date of Decision: November 10, 1986
Parties Involved
- Petitioner: Philippine Global Communications, Inc.
- Respondents: Hon. Benjamin Relova, in his capacity as Presiding Judge, Court of First Instance of Manila, Branch XI, Philippine Telegraph and Telephone Corporation, Capitol Wireless, Inc., and Radio Communications of the Philippines, Inc.
Procedural Background
- The petitioner seeks to overturn a decision rendered on April 27, 1982, by Judge Benjamin Relova, which declared that the petitioner lacked the authority to establish, maintain, and operate any branch or station within the Philippines, apart from its main station in Makati.
Background Facts
- On May 10, 1976, the petitioner applied to the Board of Communications (now the National Telecommunications Commission) for permission to establish a branch station in Cebu City for international telecommunications.
- This application faced opposition from private respondents.
- While the application was pending, the Board issued Memorandum Circular No. 77-13, which restricted communications operations to the Metropolitan Manila area.
- On January 16, 1979, the petitioner was granted provisional authority to establish a station in Cebu City, with a condition to cease operations once domestic carriers upgraded their facilities.
- On May 24, 1979, the Board granted final authority for the establishment of a branch/station in Cebu City.
- Respondents filed a petition for declaratory judgment regarding the interpretation of the petitioner’s franchise, leading to the lower court's ruling.
Legal Issues
- Whether the petitioner is authorized under its legislative franchi