G.R. No. 34331; September 3, 1931
ILOILO COMMERCIAL AND ICE COMPANY, plaintiff-appellant, vs. PUBLIC SERVICE COMMISSION, defendant-appellee.

FACTS

The Iloilo Commercial and Ice Company (formerly Iloilo Ice and Cold Storage Company) was previously held not to be a public utility. The legislature later amended the Public Service Law (Act No. 3108, as amended by Act No. 3316) to expand the definition of “public service” to include entities operating “for hire or compensation.” Based on complaints and an investigation, the Public Service Commission directed the filing of a criminal action against the company for operating an ice plant without the required certificate of public convenience. The company then filed a complaint in the Court of First Instance of Iloilo seeking an injunction to restrain the Commission from enforcing the law against it, arguing the law was unconstitutional as it deprived the company of property without due process.

ISSUE

Whether a Court of First Instance has jurisdiction to issue an injunction to restrain the Public Service Commission from enforcing the Public Service Law.

RULING

No. The Court of First Instance lacks jurisdiction to issue a restraining order against the Public Service Commission. The Public Service Law vests the Commission with powers and prerogatives similar to those of a Court of First Instance and provides that any order of the Commission may be reviewed only by the Supreme Court via certiorari or petition. Granting such injunctive power to Courts of First Instance would cause confusion and interfere with the Commission’s functions. The company has adequate legal remedies, such as raising its constitutional defense in the criminal action or following the review procedure under the Public Service Law. The Court affirmed the denial of the injunction without addressing the constitutional challenge to the law.

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