Mendoza v. Public Service Commission
REITERATIONFacts
The Antecedents: The underlying dispute concerns amendments and conversions of certificates of public convenience for taxicab operations. Petitioner Miguel M. Mendoza alleged that the Public Service Commission granted these amendments and conversions without the required hearings, thereby violating procedural due process. Specifically, private respondents were allowed to operate taxicabs within Manila and its suburbs, and to extend operations to Luzon, with a total of 600 units. A second group of private respondents sought to convert their provincial taxicab services to city operations. Procedural History: The petitioner initiated this certiorari proceeding with a preliminary injunction after alleging that the Public Service Commission granted amendments to operating authorities without proper hearings. The Commission, through Commissioner Cadiao, allegedly approved an application for conversion of taxicab units from provincial to city operations without a prior hearing. Subsequently, another group of private respondents also sought conversion of their services. Despite the petitioner's insistence on adducing evidence and the withdrawal of some oppositions, the Commission, through Commissioner Medina, declared the petition uncontested and granted the request. Motions for reconsideration were filed by the petitioner. The Supreme Court required respondents to file an answer and issued a temporary restraining order. The Petition: This case reached the Supreme Court via a petition for certiorari, alleging a violation of procedural due process by the Public Service Commission. The petitioner argued that crucial amendments and conversions of certificates of public convenience were granted without affording him and other oppositors the opportunity for a hearing. While the respondents contended that appeal was the proper remedy and that the petitioner was in default, the Supreme Court found the procedural due process claim significant enough for review. However, due to the subsequent abolition of the Public Service Commission and its replacement by a Board of Transportation under Presidential Decree No. 101, the case was rendered moot and academic, rendering a decision on the merits unnecessary.
Issue(s)
Whether the Public Service Commission denied petitioner due process by granting amendments to certificates of public convenience without the required hearing. Whether the case is moot and academic due to the subsequent abolition of the Public Service Commission.
Ruling
The case is dismissed for being moot and academic.
Ratio Decidendi
On the issue of denial of procedural due process: The Court acknowledged the petitioner's claim that the Public Service Commission might have granted amendments to certificates of public convenience without affording the petitioner the opportunity for a hearing. The Court noted that such a practice, if proven, could be viewed as an improvident exercise of authority and a violation of the due process clause. The Court recognized the significant legal question raised by the petitioner regarding the procedural regularity of the PSC's actions. However, the Court ultimately did not rule on the merits of this procedural due process claim. On the issue of the case being moot and academic: The Court found that the case had become moot and academic due to subsequent supervening events. Specifically, the Public Service Commission, the respondent agency whose actions were under scrutiny, was abolished by Presidential Decree No. 101 less than four months after martial law was declared. A Board of Transportation was created in its place to handle the functions previously exercised by the PSC. Consequently, any decision on the merits of the petitioner's claims would serve no useful purpose as the agency involved no longer existed.
Main Doctrine
A case becomes moot and academic when the agency whose actions are being questioned is abolished by law, rendering any decision on the merits without practical utility.