Title
Philippine Global Communications, Inc. vs. Relova
Case
G.R. No. L-52819
Decision Date
Oct 2, 1980
Philippine Global Communications sought to establish a Cebu branch for international telecom services, facing opposition. Jurisdictional dispute arose over legislative franchise interpretation, resolved by the Supreme Court favoring judicial review over administrative action.

Case Summary (G.R. No. L-52819)

Facts of the Case

The petitioner, Philippine Global Communications, Inc., submitted an application to the Board of Telecommunications on May 10, 1976, seeking authority to establish a branch for international telecommunications services in Cebu City. This application met with opposition from the Solicitor General and private respondents. On March 9, 1979, the Board of Communications acknowledged the petitioner’s rights under its legislative franchise but required prior approval for establishing branches. Subsequently, the private respondents contested the Board's jurisdiction regarding the petitioner’s application, leading to a motion for reconsideration that remains unresolved.

Jurisdictional Conflict

On August 27, 1979, the private respondents initiated a declaratory judgment action in court concerning the scope of the petitioner’s legislative franchise, which resulted in the case being assigned to Judge Relova. The petitioner moved to dismiss the case, arguing that it pertained to the jurisdiction of the National Telecommunications Commission. However, the respondent Judge denied this motion on January 15, 1980, deeming the grounds for dismissal not indisputable, prompting the petitioner to seek certiorari and prohibition from the higher court.

Court's Preliminary Actions

On March 6, 1980, the Supreme Court required the respondents to submit an answer within ten days and issued a temporary restraining order to maintain the status quo during the pending review of the petition. This indicated the court's acknowledgment of the need for judicial intervention before further administrative consideration of the case.

Respondents' Arguments

Respondents opposed the petitioner’s claims, emphasizing the ambiguity in the franchise concerning the establishment of branches outside Manila. They argued that the legislative franchise only permitted communications through a “sole gateway” located in Manila and did not expressly authorize the establishment of additional branches for domestic service activities, which would mischaracterize their operations as domestic rather than international.

Consideration of Primary Jurisdiction

The central legal question before the court was whether the matter constituted an appropriate case for judicial intervention through declaratory relief or if it was contingent on administrative agency action, thus adhering to the principle of primary jurisdiction. The court asserted that the lack of clarity regarding the franch

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