Manila Electric Company v. Commissioner of Public Service
REITERATIONFacts
The Antecedents: Dr. Pedro Gil, Assemblyman from the Second District of Manila, filed a complaint (Case No. 46482) with the Public Service Commission (PSC) seeking a reduction of electrical rates for residential service by the Manila Electric Company (Meralco). Concurrently, Meralco filed an application (Case No. 47991) to cancel existing rate schedules and temporarily approve revised ones. The PSC set both cases for joint hearing despite Meralco's objection regarding the PSC's jurisdiction over Case No. 46482 due to a prior dismissal order. Procedural History: The PSC ruled that it could proceed under Article 17-(a) of Commonwealth Act No. 146, allowing it to act without prior notice based on Assemblyman Gil's complaint, but would hear all evidence. Meralco submitted amended rate schedules, which were further modified by the respondent commissioner by reducing minimum charges. Meralco's motion for reconsideration was denied. The Petition: Meralco filed a petition for review, assigning several errors, including the PSC's consideration of unpresented evidence, its reference to a memorandum on profits without presentation, its fixing of minimum charges without sufficient evidence, its finding on Meralco's net profit percentage, and its denial of the motion for reconsideration. During oral arguments, Meralco pressed only the third assignment of error concerning the reduction of minimum charges under schedule D.
Issue(s)
Whether the respondent commissioner erred in taking into consideration a report of the auditor and a memorandum prepared by the accounting division of the Public Service Commission which were not formally presented in evidence. Whether the respondent commissioner erred in fixing minimum charges for residential service under schedules B, C, and D without sufficient evidence. Whether the respondent commissioner erred in holding that Meralco made a net profit of 12.27% on its business operations in 1936. Whether the respondent commissioner erred in overruling Meralco's motion for reconsideration.
Ruling
The Supreme Court affirmed the decision of the Public Service Commission. The petition for review was denied, and the preliminary injunction issued by the court was dissolved.
Ratio Decidendi
On the consideration of unpresented evidence (Assignments of Error I & II): The Court held that the report and memorandum in question formed part of the official records of the Public Service Commission. The commission could take notice of these records and consider them without the need for formal presentation as evidence, especially since the investigation was conducted under Commonwealth Act No. 146, granting the commission power to investigate matters concerning public services on its own initiative or upon complaint. The Court cited Manila Yellow Taxicab Co. vs. Araullo and Sambrano vs. Northern Luzon Transportation Co. in support of this principle. Therefore, these assignments of error were overruled. On the fixing of minimum charges and net profit (Assignments of Error III & IV): The Court examined the evidence regarding the reduction of minimum charges and the net profit calculation. It found that the commission's findings were reasonably supported by the evidence presented. The Court noted that Meralco's profit computation was based solely on its electrical department's operations for 1936. A legal presumption exists that rates fixed by the commission are reasonable, and the Court could not find that the Public Service Commission abused its discretion in fixing these rates. The Court cited Ynchausti Steamship Co. vs. Public Utility Commissioner and Board of Appeal. Consequently, these assignments of error were also overruled. On the motion for reconsideration (Assignment of Error V): As the other assignments of error were overruled, the fifth assignment of error, which pertained to the denial of the motion for reconsideration, did not require separate consideration. On the intervention of Dr. Pedro Gil and Radio Theater, Inc., et al.: The Court acknowledged the intervenors' prayers for modification of the PSC's decision, including the abolition of block charges and the adoption of a straight residential rate, as well as reductions for commercial and industrial consumers. However, the Court noted that the PSC had not made findings on these specific points. Citing the reasons provided for the intervention of Dr. Pedro Gil, the Court refrained from making pronouncements on matters not touched upon by the commission in its decision and not raised as specific assignments of error. The Court also considered that the legislative department had taken a hand in the matter, deeming it unfair to all parties to grant the intervenor's prayer under these circumstances. Prudence and fairness dictated that the Court affirm the PSC's decision without further pronouncement.
Main Doctrine
The Supreme Court affirmed the decision of the Public Service Commission regarding the modification of electrical rates, holding that the commission did not abuse its discretion in fixing the rates and that certain reports and memoranda forming part of the official records could be considered without formal presentation as evidence.