Raymundo Transportation Co. v. Public Service Commission
REITERATIONFacts
The Antecedents: On July 20, 1938, Lucas Resurreccion attempted to deliver a package to W.C. Olitan via the petitioner, Raymundo Transportation Co., Inc. The company's inspector refused to accept the package, citing that W.C. Olitan was an adversary of the company. Subsequently, W.C. Olitan lodged a complaint with the Public Service Commission regarding this refusal. Procedural History: Following the complaint filed by W.C. Olitan, the Public Service Commission conducted a hearing. The Commission rendered a decision finding the Raymundo Transportation Co., Inc. liable and imposed a fine of P10, along with a warning of a more severe penalty for any future offenses. This decision is now under review. The Petition: The petitioner, Raymundo Transportation Co., Inc., seeks a review of the Public Service Commission's decision. It argues that its certificate of public convenience does not obligate it to provide the service in question, nor is there any existing law, order, or regulation that penalizes such an act. The petitioner contends that its certificate, which allows for the transport of passengers and cargo, was not violated, and the refusal did not constitute unjust discrimination under Commonwealth Act No. 146.
Issue(s)
Whether the petitioner's refusal to accept the package for delivery constituted a violation of its certificate of public convenience and applicable laws. Whether the Public Service Commission has the authority to impose a fine and warning for such refusal.
Ruling
The judgment of the Public Service Commission is affirmed, with costs against the petitioner.
Ratio Decidendi
On the issue of refusal to accept the package: The petitioner's certificate of public convenience explicitly stated that the company would operate for the service of the public for the transport of passengers and carga (freight). A tariff schedule for freight was also prescribed. Therefore, the refusal to accept the package was a clear violation of one of the conditions imposed by its certificate of public convenience. Furthermore, to the extent that the refusal constituted an unjust discrimination against the respondent, it was also a violation of section 18-(b) of Commonwealth Act No. 146. This violation subjected the petitioner to the penal provision of section 21 of the same Act. The Court emphasized that public utilities are bound by the terms of their certificates and cannot arbitrarily refuse service. On the authority of the Public Service Commission: Under the provisions of the Public Service Act, the Public Service Commission possesses general supervision over all public utilities. It has the power to investigate any just cause of grievance against any of them, either upon its own initiative or upon a written complaint. The Commission is empowered to make and enforce reasonable rules and regulations and to provide for and grant relief in all proper cases. This broad supervisory power includes the authority to penalize violations of its orders and the conditions of certificates of public convenience, as demonstrated in the case of Philippine Shipowner's Association vs. Cui.
Main Doctrine
A transportation company operating under a certificate of public convenience for the transport of passengers and freight is obligated to accept packages for delivery, and refusal to do so, especially when it constitutes unjust discrimination, violates the conditions of its certificate and applicable laws, subjecting it to penalties.