Batangas Laguna Tayabas Bus Co. v. Associate Commissioner Cadiao
REITERATIONFacts
The Antecedents: The underlying dispute concerns a lease agreement between Batangas Laguna Tayabas Bus Company (BLTB) and Eastern Tayabas Bus Company, Inc. (ETBI) for bus operation certificates. The lease was set to expire on March 6, 1968. ETBI sought to acquire and register new units for operation, premised on its right to terminate the lease early, a matter also pending before the courts and arbitration. Procedural History: BLTB filed a petition for mandamus and contempt, seeking to compel the Land Transportation Commission to defer action on ETBI's request for new plates. This request was based on BLTB's assertion that an order from Public Service Commissioner Cadiao, dated November 2, 1967, which allowed ETBI to acquire units pending the lease expiration, was null and void. BLTB argued the order was beyond the Public Service Commission's jurisdiction due to ongoing arbitration and a prior Supreme Court ruling, and that it was issued without due process. ETBI moved to dismiss, alleging BLTB came with unclean hands and failed to state a cause of action, citing omissions of material facts. The Supreme Court noted that while the November 2, 1967 order was ex parte, BLTB had a subsequent hearing on its motion for reconsideration. The Petition: BLTB's initial petition sought mandamus and contempt, later amended to include certiorari, prohibition, and injunction. It aimed to halt the Land Transportation Commission from issuing plates to ETBI and to nullify the Public Service Commission's order. BLTB argued the Public Service Commission lacked jurisdiction because the dispute was subject to arbitration and a prior Supreme Court order. Furthermore, BLTB claimed a denial of procedural due process as it was not initially heard before the November 2, 1967 order. The petition was ultimately dismissed, with the Court finding the Public Service Commission had jurisdiction and that BLTB's procedural due process claim was cured by the subsequent hearing on its motion for reconsideration. The Court also admonished BLTB's counsel for failing to disclose material facts.
Issue(s)
Whether the Public Service Commission has jurisdiction over the petition to acquire and register units for operation of certificates of public convenience, despite a pending arbitration concerning the lease agreement. Whether petitioner was denied procedural due process in the issuance of the Public Service Commission's order dated November 2, 1967.
Ruling
The petition is dismissed. The Public Service Commission has jurisdiction over the matter, and the petitioner was not denied procedural due process.
Ratio Decidendi
On the issue of jurisdiction: The Supreme Court clarified that its previous ruling in Batangas Laguna Tayabas Bus Company (1966) restrained the PSC only from acting upon the application and resolving the dispute concerning the private aspect of the lease agreement, not matters involving the public interest or the public aspect of the operation of a public utility. The Court reiterated the doctrine that the PSC has no private control over a public utility in its private aspect but retains jurisdiction over matters involving public interest. The petition to acquire and register units for operating the lines of ETBCI, especially after the lease contract's expiration, is a matter properly cognizable by the PSC, as it concerns the public aspect of utility operation. This aligns with the principle established in Garcia v. Bonifacio, where the Court held that the PSC is the sole entity empowered to grant or transfer certificates of public convenience. On the issue of procedural due process: The Court found the allegation of denial of procedural due process to be without basis. While the order of November 2, 1967, was issued ex parte, the petitioner was subsequently afforded a full hearing on its petition to set aside and reconsider the order on January 24, 1968. The Court cited its settled doctrine dating back to 1935 that a plea of denial of procedural due process is not tenable if the defect of absence of notice is cured by an opportunity to be heard on a motion for reconsideration. The hearing on the motion for reconsideration provided sufficient opportunity for the petitioner to present its side, satisfying the requirements of due process, which emphasizes fairness and substance over mere form.
Main Doctrine
The Public Service Commission has jurisdiction over matters involving the public interest or public aspect of the operation of a public utility, even if a private aspect of a lease agreement is pending arbitration. A plea of denial of procedural due process is unavailing if the aggrieved party was given an opportunity to be heard on a motion for reconsideration.