G.R. No. L-32068, L-32083, L-32155, L-32374, L-32402, L-32464. October 4, 1971.
Republic of the Philippines, Amelito R. Mutuc, Mayor Antonio J. Villegas (for the City of Manila), Ramon A. Gonzalez, and Manila Electric Company (MERALCO), Petitioners, vs. Public Service Commission (PSC), its Commissioners, and Manila Electric Company, Respondents.

FACTS

These consolidated cases arose from the Public Service Commission’s (PSC) decision granting MERALCO a provisional rate increase. Various petitioners, including the Republic through the Solicitor General, a city mayor, and private citizens, challenged the PSC’s order. They raised procedural and substantive objections, arguing the hearings were conducted with undue haste and that the approved rates were unjust.
The procedural history was complex, involving multiple petitions to the Supreme Court. A critical procedural issue was that a motion for reconsideration of the PSC’s decision remained pending before the Commission en banc but could not be resolved due to a lack of quorum. This created an impasse, leaving the provisional rate increase in effect indefinitely without final administrative resolution.

ISSUE

The primary issue was whether the Supreme Court should decide the merits of the case despite the pending motion for reconsideration before the PSC en banc, and relatedly, whether the proceedings before the PSC were vitiated by a denial of due process due to inordinate haste.

RULING

The Supreme Court, in its main decision, proceeded to decide the cases on their merits. It held that under the extraordinary circumstances—specifically the PSC en banc’s inability to constitute a quorum to resolve the pending motion—the Court could and should exercise its review power to prevent a protracted injustice and to subserve the public interest. This action was deemed necessary to break the procedural deadlock.
In his concurring opinion, Justice Castro agreed with the final disposition but expressed significant reservations on procedural grounds. He found the PSC hearings were conducted with “unseemly haste,” likely because the presiding commissioner aimed to decide the case before his compulsory retirement. This rush impaired the parties’ right to be fully heard, eroding due process. While expedition is desirable, inordinate haste deserves condemnation. Justice Castro also viewed the Court’s decision to bypass the pending motion as an ad hoc solution, justified here by the demands of moral justice but not to be taken as a regular precedent. Furthermore, he advocated for a broader standing rule, arguing that city or municipal officials directly affected should also have the right to initiate rate revision cases, not solely the Solicitor General, to ensure more responsive representation of the consuming public.