National Power Corporation v. Arca
REITERATIONFacts
The Antecedents: The Philippine Power and Development Company and the Dagupan Electric Corporation, on behalf of electric plant operators, filed an injunction suit to restrain the National Power Corporation (NPC) from enforcing a revised rate of charges for electric power and energy, effective January 1, 1964. The plaintiffs alleged that the revised rates, which increased their costs by 24% and 30% respectively, were unreasonable, excessive, and unnecessary. They further contended that the revised rates had not been approved by the Public Service Commission (PSC) and that the unilateral revision and imposition of amended contracts violated their existing contracts, as it was done without prior arbitration. Procedural History: The Court of First Instance of Manila issued a writ of preliminary injunction upon the plaintiffs' posting of a P5,000.00 bond. The NPC moved to dissolve the injunction and dismiss the case, arguing that the enforcement of new rates would not violate plaintiffs' rights, cause irreparable damage, or that other legal remedies were available. The NPC also asserted that the court lacked jurisdiction to determine the reasonableness of the rates, which it claimed belonged to the PSC. The court denied the motion to dismiss and later denied the motion to dissolve the injunction. After its motion for reconsideration was also denied, the NPC filed the present petition for certiorari. The Petition: The National Power Corporation (NPC) filed a petition for certiorari, charging the respondent judge with grave abuse of discretion for refusing to dismiss the case and dissolve the preliminary injunction. The NPC's theory was that while the court might have jurisdiction over a portion of the subject matter, it lacked jurisdiction over all issues, specifically the reasonableness of the revised rates, which it contended pertained to the PSC under Republic Act 2677.
Issue(s)
Whether the Court of First Instance has jurisdiction to pass upon the reasonableness of the revised rates of the National Power Corporation. Whether Republic Act 2677 repealed the proviso in Section 2(g) of Commonwealth Act No. 120 exempting the National Power Corporation's rates from revision by the Public Service Commission. Whether the Court of First Instance has jurisdiction to issue a preliminary injunction against the enforcement of allegedly unauthorized and contractually violative rates. Whether the respondent judge committed grave abuse of discretion in denying the motions to dismiss and to dissolve the injunction.
Ruling
The petition for a writ of certiorari is denied, and the preliminary injunction heretofore issued is dissolved. Costs against petitioner National Power Corporation.
Ratio Decidendi
On the jurisdiction over the rates of the National Power Corporation: The Court held that the authority to inquire into the rates of charges for services rendered by the National Power Corporation does not devolve upon the Public Service Commission. Commonwealth Act No. 120, which created the NPC, specifically provides that its rates shall not be subject to revision by the PSC. While Republic Act 2677 amended the Public Service Act to grant the PSC jurisdiction over rates of public utilities owned by government instrumentalities, this general law cannot be construed to have repealed the specific exempting proviso in the NPC's charter. The settled rule is that a special statute is not repealed by a subsequent general statute unless the intent to repeal is manifest. The Court found no such legislative intent here, as the purpose of RA 2677 was to avoid cutthroat competition, a contingency not applicable to the NPC's service. Therefore, the PSC did not have jurisdiction over the NPC's rates under these circumstances. On the effect of Republic Act 2677: Even if Republic Act 2677 were deemed to have impliedly repealed the proviso in Section 2(g) of Commonwealth Act No. 120, the NPC's position would not improve. The new schedule of rates the NPC attempted to impose had not been previously authorized by the PSC. Consequently, the respondent power companies were justified in contesting these new rates as illegal. They were entitled to apply to the Court of First Instance for injunctive relief against the wrongful attempt to enforce unauthorized rates, as such a remedy is not obtainable from the PSC itself. Injunction is an exercise of judicial power, distinct from the administrative functions of the PSC. On the jurisdiction to issue a preliminary injunction: The Court affirmed that the respondents had the right to resort to the Court of First Instance for injunctive relief against the enforcement of rates claimed to be unauthorized by law and violative of their contracts. It was within the lower court's jurisdiction to entertain their action. The grant of the injunction was merely incidental to the court's authority to take cognizance of and adjudicate the main controversy. The argument that private respondents should have exhausted administrative remedies was dismissed, as the NPC itself claimed the rates were approved by the National Economic Council, and neither that body nor the President could adjudicate contract violations. On the alleged damages not being irreparable: The Court found the claim that damages would not be irreparable to be untenable. The losses to be suffered by the respondent companies would necessarily reduce their resources and efficiency, prejudicially involving their services to the general public to an extent that could not be determined in advance. This inherent uncertainty and potential disruption to public service constitute irreparable damage.
Main Doctrine
A special statute providing for a particular case is not repealed by a subsequent general statute unless the intent to repeal is manifest. The authority of the Public Service Commission to fix rates does not extend to the National Power Corporation if its charter provides otherwise, and even if it did, injunctive relief against unauthorized rates is within the jurisdiction of the Court of First Instance.