G.R. No. 25940 , December 18, 1926
ALEJANDRA MEJICA, petitioner, vs. THE PUBLIC UTILITY COMMISSION, respondent. FRANCIS J. COOPER, NEGROS TRANSPORTATION CO. and RAMON MIRASOL, intervenors

DOCTRINE:
The Public Utility Commission has the authority to impose conditions on public utilities, such as requiring them to operate on fixed routes and schedules, to protect regular operators from ruinous competition and to ensure adequate and reliable service for the public. The court will not interfere with the Commission’s exercise of its regulatory powers if its decision is reasonably supported by evidence.

FACTS

Alejandra Mejica, an operator of auto trucks for passenger and freight transportation, applied to the Public Utility Commission (PUC) for authority to increase her fleet by seven trucks. She operated on irregular schedules without fixed routes. The intervenors, Francis J. Cooper and Negros Transportation Co., were also public utility operators in the same territory but operated on fixed routes and schedules, as approved by the PUC. They opposed Mejica’s application. The PUC, through Assistant Commissioner M.V. del Rosario, granted Mejica’s request for additional trucks but imposed a condition: when operating on the same line as Cooper or Negros Transportation, her trucks could not depart from any point less than two hours before or one hour after the scheduled departures of the intervenors’ trucks. Mejica filed a petition for review, challenging the PUC’s order as unjust and unsupported by evidence.

ISSUE

1. Whether the PUC had the power to establish a rule protecting regular operators (with fixed routes and schedules) from the competition of irregular operators.
2. Whether there was sufficient evidence before the PUC to reasonably support the application of this rule to Mejica.

RULING

The Supreme Court AFFIRMED the decision of the Public Utility Commission.

1. On the PUC’s Power: The Court held that the PUC has the authority to impose conditions such as fixed routes and schedules on public utilities. This power is a valid exercise of its regulatory function to ensure adequate and reliable public service. The rule protecting regular operators from irregular competition is justified because regular service with fixed schedules better serves the public interest by providing certainty and proper service. The Court emphasized that it should not interfere with the PUC’s exercise of its discretion in the absence of a clear excess of jurisdiction.

2. On the Sufficiency of Evidence: The Court found that there was ample evidence before the PUC to support its decision. The PUC’s findings were based on the clear need for the additional service and the policy of favoring regularized operations for the public benefit. The Court’s role is not to re-evaluate the evidence but to determine if the PUC’s order was reasonably supported by it, which in this case, it was.

The Court treated Mejica’s filing as a petition for review (despite its label) and concluded that the PUC’s decision was within its jurisdiction and supported by evidence. Costs were imposed on petitioner Mejica.