City of Tagbilaran v. Lim
REITERATIONFacts
The Antecedents: Severiano G. Lim applied for a certificate of public convenience to operate fifty motorized tricycles for passenger transport within Tagbilaran City. The City of Tagbilaran opposed the application, asserting that the authority to grant such permits was vested in its city board and not the Public Service Commission. Procedural History: The application was heard by the Public Service Commission. The applicant presented evidence of his citizenship, financial capacity, business background, and the need for the proposed service, citing the lack of existing public transportation and the growing student population. The City of Tagbilaran also presented evidence. The Public Service Commission found that public convenience would be promoted by the grant of the application, noting the city's rapid growth and need for more transportation facilities. It also found the city's opposition unsubstantiated and potentially motivated by a fear of losing revenue from license fees. The Commission overruled the opposition and ordered the issuance of the certificate of public convenience. The Petition: The City of Tagbilaran, as oppositor-petitioner, filed a petition for review with the Supreme Court, primarily arguing that the competence to grant the privilege of operating motorized tricycles within its boundaries belonged to the City and not the Public Service Commission. It also raised other factual issues.
Issue(s)
Whether the City of Tagbilaran has the competence to grant a certificate of public convenience for the operation of motorized tricycles within its territorial jurisdiction. Whether the findings of fact by the Public Service Commission regarding public convenience and necessity are binding on the Supreme Court.
Ruling
The Supreme Court affirmed the decision of the Public Service Commission. It held that the City of Tagbilaran failed to show any statutory basis for its claim of competence to grant certificates of public convenience for motorized tricycles. The Court also reiterated that findings of fact by the Public Service Commission, when supported by evidence, are not to be disturbed by the Supreme Court.
Ratio Decidendi
On Issue 1: The Supreme Court held that the City of Tagbilaran did not possess the competence to grant a certificate of public convenience for the operation of motorized tricycles. The Court emphasized the well-settled doctrine that municipal corporations possess only such powers as are expressly delegated to them by law or necessarily implied from such express powers. It was incumbent upon the City of Tagbilaran to demonstrate that its charter, Republic Act No. 4660, expressly granted it the authority to issue such permits. The Court found no such statutory basis, noting that the provision cited by the City's fiscal merely authorized the imposition of municipal license taxes or fees on persons operating motorized tricycles, which is distinct from the power to grant a certificate of public convenience. Therefore, the City's claim of competence was unfounded. On Issue 2: The Supreme Court reiterated its consistent ruling that findings of fact made by the Public Service Commission, when supported by evidence, are binding upon the Supreme Court. The Court cited several cases, including Philippines Rabbit Bus Lines, Inc. v. Gabatin and Ledesma v. Public Service Commission, to underscore that it is not the Court's role to determine the credibility of witnesses, the preponderance of proof, or to re-examine the evidence de novo. The Court stated that it should not substitute its discretion for that of the Public Service Commission on questions of fact. Since the other errors assigned by the City of Tagbilaran were factual in character and did not demonstrate a clear showing of grave abuse of discretion or lack of jurisdiction, the findings of the Commission regarding public convenience and necessity were upheld.
Main Doctrine
The Supreme Court affirmed the decision of the Public Service Commission granting a certificate of public convenience to operate motorized tricycles, holding that the City of Tagbilaran failed to demonstrate any statutory basis for its claim that it possessed the exclusive authority to grant such permits. The Court reiterated the principle that municipal corporations only possess powers expressly delegated to them by law or necessarily implied therefrom, and the burden rests upon the municipality to prove such delegated authority. The Court also emphasized that findings of fact by the Public Service Commission, when supported by evidence, are binding upon the Supreme Court.