G.R. No. L-35812-17 February 23, 1973
EMILIANO O. OZAETA, REMIGIO CASTILLO and CONFERENCE OF INTER-ISLAND SHIPOWNERS AND OPERATORS, petitioners, vs. OIL INDUSTRY COMMISSION, ESSO PHILIPPINES, INC., MOBIL OIL PHIL., INC., CALTEX (PHIL.) INC., GETTY OIL (PHIL.), INC., SHELL PHILIPPINES, INC., FILOIL REFINERY CORP., and FILOIL MARKETING CORPORATION, respondents.

FACTS

Petitioners challenged a decision of the respondent Oil Industry Commission (OIC) dated September 18, 1972, which authorized an across-the-board price increase for petroleum products. They argued the decision lacked evidentiary support. In response, the Supreme Court, in a resolution dated December 29, 1972, granted a joint motion by the private respondent oil companies and remanded the cases to the OIC. The remand order directed the OIC to receive and study specific technical data from the parties—covering financial conditions, asset appraisal, product costs, and the cost matrix used—and thereafter to render a new decision.
Subsequently, petitioners filed an “Urgent Motion to Recall Order of Remand” on January 14, 1973, alleging the OIC was not disposed to follow the Court’s directive. After the OIC rendered a new decision on rehearing, petitioners filed an “Urgent Omnibus Motion” on January 25, 1973, asserting this new decision was contrary to the terms of the remand. Both motions effectively sought reconsideration of the December 29, 1972 resolution, asking the Court to set it aside and directly rule on the merits of their original petition.

ISSUE

Whether the Supreme Court should recall its resolution remanding the cases to the Oil Industry Commission for a new decision based on further study of technical data.

RULING

The Supreme Court denied both motions and refused to recall the remand order. The legal logic is anchored on the doctrine of primary jurisdiction and the proper role of judicial review over administrative agencies. The Court emphasized that its function is not to resolve factual and technical matters in the first instance, especially concerning complex economic regulations like oil pricing. The remand was precisely intended to allow the specialized administrative body, the OIC, to complete its fact-finding and analysis based on the specified data, a task for which it is technically competent.
The Court found petitioners’ allegations of the OIC’s non-compliance unpersuasive. A perusal of the OIC’s new decision on rehearing demonstrated that it had, in fact, considered the issues outlined in the remand resolution with care. The Court clarified it was not ruling on the legal correctness of that new decision but was merely determining that the OIC had undertaken the ordered study. To recall the remand would thrust the Court into resolving technical evidentiary details, which is inappropriate. The Court held that if the new OIC decision ultimately suffers from legal infirmities, such as a lack of substantial evidence or a denial of due process, petitioners could seek judicial review on those specific grounds in the proper proceedings. Until such a clear legal question is appropriately raised, the Court must allow the administrative process to run its course.