G.R. No. L-24198 & L-24207-10 December 18, 1968
PHILIPPINE LONG DISTANCE TELEPHONE COMPANY, petitioner, vs. PUBLIC SERVICE COMMISSION, respondent.

FACTS

The Philippine Long Distance Telephone Company (PLDT) appealed from two orders of the Public Service Commission (PSC). The first order, dated August 13, 1964, directed PLDT to complete by August 25, 1964, the repair of all telephone troubles in Manila and suburbs caused by typhoon “Dading” or other factors, and to repair within five days any troubles reported after August 20, 1964, under penalty of a daily fine of P50.00 for non-compliance. The second order, dated February 3, 1965, denied PLDT’s motion for reconsideration. The orders arose from numerous subscriber complaints about inadequate and discriminatory repair services following the typhoon on June 29-30, 1964. During the hearing, PLDT justified the delay by citing the extensive damage to its facilities, difficulties in repair work, and a shortage of trained technical personnel. In contrast, a witness for the complainants, an expert telephone engineer, testified that the damages could have been repaired within thirty days, suggesting PLDT could have sought cooperation from other telephone systems or government agencies.

ISSUE

The issues were: (1) Whether the Public Service Commission committed reversible error by denying PLDT’s motion for reconsideration without conducting a hearing en banc as allegedly mandated by law; and (2) Whether the PSC’s factual findings and the imposition of the fine were arbitrary and unsupported by substantial evidence.

RULING

The Supreme Court affirmed the PSC’s orders. On the first issue, the Court held that while the Public Service Act provides for a hearing on a motion for reconsideration, strict observance was not imperative in this case. PLDT’s 23-page motion comprehensively discussed its grounds, and the Commission had access to the transcript and exhibits. Thus, the resolution without oral argument did not deprive PLDT of due process, as no material prejudice was shown, and administrative bodies like the PSC are not strictly bound by procedural rules provided no cardinal rights are sacrificed. On the second issue, the Court found the PSC’s conclusion—that the repairs could have been completed earlier—was supported by substantial evidence. PLDT’s own witness indicated that 85-90% of the work was done by early August, with a large workforce deployed. The PSC’s order to complete repairs by August 25 was reasonable. The Court also rejected the claim that the fine was arbitrary, noting there was no evidence the order applied to disruptions unrelated to typhoon “Dading,” and arguments based on hypothetical future events were not entertained. Costs were taxed against PLDT.