Laoag City v. Public Service Commission
REITERATIONFacts
1. The Antecedents: The City of Laoag and the Municipality of San Nicolas, Ilocos Norte, along with their consuming public, had lodged protests against the Ilocos Norte Electric Company, Inc. (INELCO) for alleged inefficient management, inadequate power supply characterized by low voltage and frequent brown-outs, and exorbitant rates. These issues formed the basis of the dispute that led to the Public Service Commission (PSC) proceedings. 2. Procedural History: Following the protests, INELCO initially reduced its rates by 5% effective January 1, 1960, which was approved by the PSC. Further negotiations and hearings ensued, leading to proposed new rates and a committee being formed to facilitate an amicable settlement. Despite an alleged agreement between INELCO and the mayors for an 8% reduction, its validity was questioned. The PSC allowed examination of INELCO's books, and a committee report was submitted. On April 17, 1968, the PSC issued a decision authorizing INELCO to charge its rates reduced by a total of 8% (5% from January 1, 1960, and 3% voluntarily from January 1, 1963), aside from existing reductions for municipal and street lighting, finding that a retroactive reduction to August 1959 would cause financial dislocation. Petitioners filed a motion for reconsideration on June 18, 1968, which was denied on May 21, 1970. 3. The Petition: The petitioners filed a petition for review with the Supreme Court on June 18, 1970, assigning as errors the PSC's sustaining of allegedly exorbitant rates despite INELCO's deficient service and its disregard of the petitioners' proposed reduced rates. However, during the pendency of this petition, a new case (PSC Case No. 71-2390) was filed for rate reduction, resulting in a compromise agreement approved by the PSC on April 24, 1972. This agreement, which established new, lower rates, was deemed by the PSC and INELCO to have rendered the present petition moot and academic. Furthermore, the Court noted that the petition was filed out of time, as the motion for reconsideration was filed 19 days after the petitioners' counsel obtained a copy of the PSC decision on May 30, 1968, exceeding the 15-day reglementary period.
Issue(s)
Whether the petition for review has been rendered moot and academic by the subsequent compromise agreement approved by the PSC. Whether the petition for review was filed within the reglementary period. Whether the PSC erred in sustaining the rates charged by INELCO despite alleged deficient service and in disregarding petitioners' proposed rates.
Ruling
The petition for review is dismissed. The Supreme Court found that the case was rendered moot and academic by the compromise agreement approved by the PSC on April 24, 1972. Furthermore, the petition was dismissed for having been filed out of time.
Ratio Decidendi
On the issue of mootness due to compromise agreement: The Supreme Court held that the subsequent compromise agreement entered into by the parties in PSC Case No. 71-2390, and approved by the PSC en banc on April 24, 1972, rendered the present petition moot and academic. The Court cited the principle that the nature of a compromise agreement is to supersede all prior agreements and proceedings, constituting a final and definite settlement of controversies. The petitioners' inaction in commenting on the compromise agreement was deemed an implicit acceptance, binding them to its terms. The rates approved in the compromise agreement were also noted to be lower than those previously approved and sought to be reviewed, indicating that the petitioners, by agreeing to them, acknowledged their reasonableness. On the timeliness of the petition: The Supreme Court found that the petition was filed out of time. The decision of the PSC was served on petitioners' counsel by registered mail on April 25, 1968. Although the mail was returned unclaimed due to the counsel's failure to notify the PSC of his change of address, the counsel admitted to obtaining a copy of the decision on May 30, 1968. A motion for reconsideration was filed on June 18, 1968, which was 19 days after May 30, 1968. This exceeded the 15-day reglementary period for filing a motion for reconsideration under Section 34 of the Public Service Act. Consequently, the decision became final on June 29, 1968, as no appeal by way of petition for review was filed within the 30-day period from May 30, 1968, as prescribed by Section 36 of the same Act. The Court emphasized that the perfection of an appeal within the prescribed period is jurisdictional. On the alleged PSC error in sustaining rates and disregarding proposed rates: This issue was rendered moot and academic by the subsequent compromise agreement. However, the Court also noted that the assignment of errors raised purely questions of fact, and it is not the Court's role to re-examine evidence or substitute its discretion for that of the PSC on factual matters, citing previous rulings. The Court reiterated its consistent stance that where a petition for review disputes merely the sufficiency of the evidence, the findings of the PSC cannot be disturbed.
Main Doctrine
A petition for review before the Supreme Court may be rendered moot and academic by a subsequent compromise agreement entered into by the parties, which agreement supersedes all prior agreements and proceedings, constituting a final settlement of controversies. Furthermore, the timeliness of filing a motion for reconsideration and subsequent appeal is jurisdictional, and failure to comply with prescribed reglementary periods renders the decision final and executory.