Rural Transit Co. v. Teodoro
REITERATIONFacts
1. The Antecedents: The Rural Transit Company, Ltd. filed two complaints with the Public Service Commission seeking the cancellation of the respondent's (Anastacio R. Teodoro, Associate Commissioner, Public Service Commission, and Santos-Relucio-Soriano) certificate of convenience to operate motor bus lines between Cabiao and Manila via Bulacan and Pampanga, and between Cabiao and San Fernando. The basis for cancellation was the alleged failure of the respondent to operate these lines for four consecutive days, which under the Commission's rules, results in automatic cancellation. 2. Procedural History: The Public Service Commission dismissed the complaints on March 9, 1932, before the complainant presented evidence. Although the respondent admitted default and the cancellation of his Cabiao-Manila certificate, the Commission, in its discretion, permitted him to continue operating a portion of the line, specifically Cabiao-Arayat. The Rural Transit Company objected to this discretionary allowance. 3. The Petition: The Rural Transit Company, Ltd. initiated an original proceeding in the Supreme Court seeking a writ of mandamus to compel the cancellation of the respondent's certificate for the Cabiao-Arayat line. The petition argued that the Commission's decision was erroneous. However, the Supreme Court, noting that the matter was within the Commission's discretion and that a petition for review under Act No. 3108 would have been the appropriate procedural remedy, denied the writ of mandamus. The denial was affirmed upon reconsideration, and the appeal was dismissed.
Issue(s)
Whether a writ of mandamus is the proper remedy to question the discretionary act of the Public Service Commission in allowing the continued operation of a portion of a cancelled bus line. Whether the Supreme Court can interfere with the discretionary powers of the Public Service Commission.
Ruling
The Supreme Court affirmed the decision of the Vacation Justice denying the writ of mandamus and dismissed the appeal. The Court held that the matter of allowing the respondent to continue operating the Cabiao-Arayat line was within the discretion of the Public Service Commission, and therefore, mandamus was not the proper remedy.
Ratio Decidendi
On the propriety of mandamus: The Court held that mandamus is an extraordinary remedy that lies to compel a ministerial duty, not to control discretion. In this case, the Public Service Commission exercised its discretion when it allowed the respondent to continue operating a part of the line, Cabiao-Arayat, despite the admitted default on other routes. The petitioner's objection to this discretionary act cannot be addressed through a writ of mandamus. The Court emphasized that even if the decision of the commission was perceived as erroneous by the petitioner, it does not warrant the issuance of a writ of mandamus. The proper recourse for challenging such a decision would be through a petition for review as provided by law. On the interference with the Commission's discretion: The Court reiterated that matters falling within the sound discretion of administrative bodies like the Public Service Commission are generally not subject to judicial interference through extraordinary remedies like mandamus. The commission has the authority to manage and regulate public utilities, which includes making decisions regarding certificates of convenience and their operation. The petitioner's disagreement with the commission's exercise of discretion does not automatically grant the Supreme Court the power to substitute its judgment for that of the commission via a writ of mandamus. The Court found that the commission had already made a decision on the petitioner's complaints, and the petitioner's recourse was to appeal that decision, not to seek a writ of mandamus.
Main Doctrine
A writ of mandamus does not lie to compel a public service commission to reverse a discretionary decision, even if perceived as erroneous by a party; the proper remedy is an appeal or petition for review.