Vidal v. Public Service Commission
REITERATIONFacts
The Antecedents: Pedro Vidal executed a deed of sale on May 16, 1961, transferring to David Baetiong a certificate of public convenience allegedly granted to Vidal in PSC Case No. 63708, along with several jeepneys, for P7,000.00. Procedural History: An application for the approval of this sale was filed by Vidal and Baetiong with the Public Service Commission (PSC Case No. 614668). The PSC provisionally approved the sale on June 6, 1961, subject to revocation. After a hearing, the PSC dismissed the application and set aside the provisional approval on November 29, 1961, citing the absence of any record of the certificate of public convenience issued to Vidal in PSC Case No. 63708. The plates of the jeepneys were ordered confiscated. A motion for reconsideration was filed, seeking a formal inquiry and postponement of confiscation. An amended motion was filed on February 8, 1963, requesting the setting aside of the dismissal order, return of plates, and a new hearing to present documents allegedly evidencing the certificate. The Petition: Petitioners filed a petition for review with the Supreme Court on July 7, 1965, challenging the PSC's denial of their motion for reconsideration. The primary issue raised was whether the PSC should have ruled on the basis of newly offered documents that a certificate was indeed issued to Vidal in Case No. 63708.
Issue(s)
Whether the Public Service Commission erred in denying the motion for reconsideration and refusing to consider the newly presented documents as proof of the existence of a certificate of public convenience. Whether the provisional approval of the sale and transfer of the certificate of public convenience, which was later revoked, affects the main issue of the certificate's existence.
Ruling
The Supreme Court affirmed the orders of the Public Service Commission. The Court held that the PSC did not err in denying the motion for reconsideration and the presentation of the alleged certified true copy of a decision, as it could not prevail over the absence of official records. The provisional approval was also correctly revoked.
Ratio Decidendi
On Issue 1: The Supreme Court held that the Public Service Commission did not err in denying the motion for reconsideration and refusing to consider the newly presented documents. The PSC en banc had determined, based on sworn statements from personnel in charge, that no record of a certificate of public convenience awarded to Pedro Vidal in Case No. 63708 could be found, nor was its docket, statistical record, or time schedule available. The Court reasoned that a certified true copy of an alleged decision cannot prevail over the official records of the Commission unless it is shown that these records are defective or incomplete, which was not established. The Court concluded that the so-called certified true copy was likely fraudulently made, and there was no convincing proof of the decision's existence. Therefore, the PSC was not obligated to rely on such a document in the absence of any supporting official records or competent proof of its promulgation. On Issue 2: Regarding the provisional approval of the sale and transfer, the Supreme Court stated that its terms allowed for revocation at any time and was intended only for the pendency of the application. Thus, the fact of its grant and recording did not impact the core issue of whether a certificate of public convenience was actually issued to Vidal. Furthermore, the Court noted that even this provisional approval was found to have been granted due to forgeries in the initials of the personnel who recommended action, justifying its proper revocation. The Court clarified that the vendee's recourse for alleged injustice lies against the vendor for recovery, and the vendor's recourse is against those responsible for the fraud, but the present suit's focus remained on the non-existence of the certificate and the consequent invalidity of its sale.
Main Doctrine
The Supreme Court affirmed the Public Service Commission's denial of an application for the approval of a sale of a certificate of public convenience, holding that the existence of such a certificate must be proven by official records. The Court found that a certified true copy of an alleged decision granting the certificate could not prevail over the Commission's sworn statement that no such record existed, implying the copy was fraudulent. Consequently, the sale of a non-existent franchise and the operation of vehicles under it were not permissible.