Manila Electric Co. v. Medina
REITERATIONFacts
The Antecedents: Manila Electric Company (MERALCO) applied for revised (increased) rate schedules, terms, and conditions. The Public Service Commission (PSC), after hearing, approved the proposed "Terms and Conditions of Service" and "Rules and Regulations" but reduced the proposed rate increases. The decision explicitly stated that the approved increases "shall be effective from the date of this decision." Procedural History: Following the promulgation of the decision, the Solicitor General filed a petition for reconsideration and, on the same day, moved ex parte to suspend the effectivity of the decision. The PSC issued an order suspending the effectivity without notice or hearing to MERALCO. MERALCO's motion for a hearing to oppose the suspension was not acted upon. Subsequently, other motions for reconsideration were filed, and Commissioner Medina issued several orders regarding the calendaring and hearing of these motions, which MERALCO alleged were designed to delay resolution. The Petition: MERALCO filed a petition for certiorari to set aside the PSC's order suspending the rate increases and to delay hearings on motions for reconsideration, and for a writ of mandamus to compel the PSC to immediately hear and resolve the motions for reconsideration. MERALCO contended that the orders were invalid, without or in excess of jurisdiction, and that Commissioner Medina was engaged in a scheme to delay the proceedings.
Issue(s)
Whether the Commission acted in accordance with law in suspending the effectivity of its decision. Whether Commissioner Medina, acting alone, had the authority to issue the questioned orders.
Ruling
The Court granted the writs prayed for. The order of the respondent Commission dated March 19, 1965, suspending the effectivity of the rate increases previously authorized, was declared illegal, null and void. The respondent Public Service Commission was directed to immediately hear and promptly resolve the motions for reconsideration of its main decision dated March 15, 1965.
Ratio Decidendi
On the issue of the Commission's authority to suspend the effectivity of its decision: The Public Service Law, specifically Section 33, clearly mandates that "All orders of the Commission to continue on existing service or prescribing rates to be charged shall be immediately operative." The law confers no discretion upon the Commission to suspend the effectivity of such orders. The absence of any qualifying phrase, such as "unless the Commission provides otherwise," further emphasizes this mandatory nature. The express grant of power to the Supreme Court to stay Commission orders via a writ of certiorari under Section 37, in contrast to the Commission's silence on such power, reinforces the conclusion that the law intended to deny the Commission any authority to suspend the immediate operation of rate-prescribing orders. The argument that the power to suspend is implied in the power to reconsider is untenable, as express statutory provisions must be followed. Furthermore, the argument that rate orders affect many people does not justify implying a power that the Legislature deliberately omitted. The Court also found the suspension order invalid because it was issued ex parte without notice or hearing to MERALCO, thus denying due process. The suspension order, in effect, amended the original decision which explicitly stated that increases were effective from the date of the decision, and such an amendment without due process is illegal. The principle that the due process clause binds all branches and agencies of government, including administrative bodies like the PSC, was reiterated. On the issue of Commissioner Medina's authority to issue orders alone: Section 3 of the Public Service Act provides that any motion for reconsideration or non-interlocutory order "shall be heard directly by the Commission en banc" and requires the concurrence of at least four Commissioners for a final decision or order resolving such motion. When the Solicitor General filed a motion for reconsideration, jurisdiction vested in the Commission en banc, and Commissioner Medina could not act alone unless such power was properly delegated. However, the Court found it unnecessary to further pursue this matter as the periods for filing motions and oppositions had elapsed, and there was no longer any obstacle to the Commission hearing the motions en banc immediately, as required by Section 34 of the Public Service Act.
Main Doctrine
The Public Service Commission has no authority to suspend the effectivity of its orders prescribing rates to be charged, as such orders are immediately operative by law. Furthermore, any order suspending the effectivity of a rate increase decision, issued ex parte and without notice and hearing to the affected party, is invalid and violative of due process.