Pangasinan Transportation Co. v. Pampanga Bus Co.
REITERATIONFacts
The Antecedents: Pampanga Bus Company (Pambusco) filed an application with the Public Service Commission (Commission) for a certificate of public convenience to operate a public utility bus (PUB) service on various routes, initially from Camiling, Tarlac to Cubao, Quezon City, then amended to Baguio City to Cubao, Quezon City, and finally to Baguio City to Bonifacio Monument, Caloocan City. Oppositions were filed by Pangasinan Transportation Co., Inc. (Pantranco), Dangwa Transportation Co., Inc. (Dangwa), and Philippine Rabbit Bus Lines, Inc. (Philippine Rabbit). Procedural History: Numerous postponements of hearings were granted at the request of Pambusco. The Commission suggested and conducted two "checks" of passenger traffic volume along the proposed routes. Pambusco also filed applications for provisional permits. On April 27, 1965, the Commission issued an order imposing a moratorium on new certificates of public convenience. Despite this, the Commission issued an order dated September 3, 1965, granting Pambusco a provisional permit to operate a PUB service on the Baguio City-San Fernando, Pampanga run. Oppositors received this order on September 23, 1965, and filed the instant petition for certiorari on September 29, 1965, alleging abuse of discretion and seeking a writ of preliminary injunction, which was granted. The Petition: Petitioners filed a petition for certiorari with the Supreme Court, alleging grave abuse of discretion on the part of the Public Service Commission in issuing the order granting Pambusco a provisional permit to operate a PUB service on the San Fernando, Pampanga-Baguio City line. They sought to restrain Pambusco from carrying out this order. Subsequently, the Commission rendered a decision on October 30, 1969, authorizing Pambusco to operate ten (10) auto-trucks on the Cubao, Quezon City-Baguio City route. Philippine Rabbit filed a motion for reconsideration, which was withdrawn. The Supreme Court, on December 3, 1970, required the parties to show cause why the petition should not be considered moot and academic, noting that Pambusco was already operating on the Cubao-Baguio City line, frustrating the relief sought by petitioners.
Issue(s)
Whether the petition for certiorari had become moot and academic due to supervening events. Whether the Public Service Commission committed grave abuse of discretion in granting a provisional permit to Pambusco.
Ruling
The Supreme Court dismissed the petition for certiorari, holding that the issues raised had become moot and academic. The Court found that the provisional permit granted to Pambusco had expired by its own terms, and Pambusco was already operating on the Cubao, Quezon City-Baguio City line by virtue of a subsequent decision of the Commission, which rendered the original petition moot.
Ratio Decidendi
On Issue 1: The Court found that the petition had become moot and academic due to two primary considerations. Firstly, the provisional permit granted to Pambusco on September 3, 1965, was explicitly stated to be valid only for a period of six (6) months from its date. Therefore, by the mere lapse of time, the permit had expired and ceased to be valid, obviating the need for the Court to rule on its validity. Secondly, Pambusco was already operating a PUB service on the Cubao, Quezon City-Baguio City line by virtue of the Commission's decision dated October 30, 1969. This subsequent authorization covered the same route that was the subject of the provisional permit, thereby defeating the ultimate relief sought by the petitioners, which was to restrain Pambusco from operating on that line. Consequently, any judgment on the merits of the petition would have no practical value or effect. On Issue 2: The Court did not pass upon the alleged grave abuse of discretion by the Commission in granting the provisional permit. Because the issues were rendered moot and academic by supervening events, the Court deemed it unnecessary to articulate an extended opinion on the merits of the petition. The dismissal of the petition on the ground of mootness rendered the question of whether the Commission committed grave abuse of discretion in issuing the provisional permit irrelevant.
Main Doctrine
The Supreme Court dismissed the petition for certiorari as moot and academic because the issues raised had lost their practical significance due to supervening events. Specifically, the provisional permit granted to Pambusco had expired by its own terms, and Pambusco had subsequently been granted a certificate of public convenience to operate on the same route, thereby rendering any ruling on the provisional permit moot. The Court reiterated that it will not pass upon issues that no longer have any practical value or effect.