G.R. No. 40977 , 40982, 40983; April 21, 1934
PANAY AUTOBUS CO. and JOVITA ALFARAS, petitioners-appellants, vs. ILOILO TRANSPORTATION CO., INC., and PANAY AUTOBUS CO., respondents-appellees.

FACTS

Three operators—Jovita Alfaras, Panay Autobus Co., and Iloilo Transportation Co., Inc.—were providing autobus service in Iloilo and its suburbs. Panay Autobus and Iloilo Transportation applied with the Public Service Commission to enlarge their routes and increase their equipment. Each operator objected to the others’ applications. Alfaras’s service, while covering the desired routes, was inadequate and irregular due to insufficient equipment. The other two companies had adequate capital and management, offering high-class service, though with potentially excessive or impractical equipment proposals. The Public Service Commission granted the applications of Panay Autobus and Iloilo Transportation, effectively allowing them to extend their operations into areas served by Alfaras.

ISSUE

Whether the Public Service Commission erred in granting the applications of Panay Autobus Co. and Iloilo Transportation Co., Inc., to extend their routes and increase their equipment over the objections of the existing operator, Jovita Alfaras.

RULING

No. The Supreme Court affirmed the orders of the Public Service Commission. The Court found that the extensions were slight and for public benefit, and that Alfaras’s service was inadequate to meet public demand. While the Court noted potential concerns over ruinous competition and financial risks, it held that there was evidence in the record to support the Commission’s factual conclusion that the grants were justified. The Court reiterated its policy of non-interference with the Commission’s factual determinations absent a lack of evidence, as no new question of law was presented.

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