San Nicolas Transportation Company v. Public Service Commission
REITERATIONFacts
The Antecedents: Petitioner, San Nicolas Transportation Company, a holder of a certificate of public convenience operating an auto-truck service, was found guilty of violations of orders of the Public Service Commission (PSC) on November 7, 1931, and was imposed a fine of P700 plus P25 for costs of investigation. A motion for reconsideration and new hearing was filed, but no decision was rendered until July 31, 1933, when the PSC denied the motion and sustained its original decision. Procedural History: On September 26, 1933, the PSC issued an order suspending the operation of petitioner's auto-truck service due to its failure to pay the imposed fine and costs, and requested the recall of its TPU plates. Petitioner filed an original application for certiorari to review this order. The Petition: Petitioner seeks to annul the order of the PSC dated September 26, 1933, and to be granted the writ of certiorari.
Issue(s)
Whether the Public Service Commission has the authority to impose fines and costs upon a holder of a certificate of public convenience. Whether the order of the Public Service Commission suspending the operation of the petitioner's auto-truck service due to non-payment of an imposed fine is legal and valid.
Ruling
The Supreme Court granted the writ of certiorari and vacated the order of the Public Service Commission dated September 26, 1933. The Court held that the PSC was without authority to impose such fines and costs, rendering its subsequent order of suspension illegal and arbitrary.
Ratio Decidendi
On the authority of the Public Service Commission to impose fines: The Supreme Court held that the Public Service Commission, being a creature of the legislature, can only exercise such jurisdiction and powers as are expressly or by necessary implication conferred upon it by statute. The Court found no delegation of authority in express words or by necessary implication in section 30 or any other provision of the Public Service Law that would grant the commission the power to determine guilt, discretion to fix penalties, or the authority to impose fines under pain of suspension of a certificate of public convenience. Therefore, the commission was without jurisdiction to make the order imposing the fine. On the legality and validity of the suspension order: Since the Public Service Commission was without authority to impose the fine, its action in attempting to enforce such a fine by suspending the petitioner's operation and taking away its plates was deemed illegal and arbitrary. Orders predicated upon an illegal fine cannot be upheld. The Court explicitly cited its previous ruling in Filipino Bus Company vs. Philippine Railway Company, respondent, and Public Service Commission, intervenor, promulgated February 16, 1933 (57 Phil., 860), which held that the PSC was without authority to impose such fines. Consequently, the order of September 26, 1933, which was based on this illegal fine, had to be vacated.
Main Doctrine
The Public Service Commission is without authority to impose fines and costs, and its orders predicated upon such illegal fines are void and cannot be upheld. The enforcement of such fines through the suspension of a certificate of public convenience is illegal and arbitrary.