GR 37929; (February, 1933) (Digest)
G.R. No. 37929 ; February 16, 1933
FILIPINO BUS COMPANY, petitioner, vs. PHILIPPINE RAILWAY COMPANY, respondent. PUBLIC SERVICE COMMISSION, intervenor.
FACTS
The Public Service Commission (PSC) imposed a fine of P500 plus costs on the Filipino Bus Company for violating its authorized fare schedules by charging lower fares in January and February 1932. The company, in its defense before the PSC, did not present evidence but submitted a manifestation admitting it engaged in rate-cutting due to competitive necessity in Cebu province. The company petitioned the Supreme Court to review the PSC’s order, arguing the penalty was excessive and later questioning the PSC’s jurisdiction to impose such a fine.
ISSUE
Whether the Public Service Commission had jurisdiction to impose a fine and order the suspension of certificates for non-payment.
RULING
No. The Supreme Court vacated the PSC’s order as void for lack of jurisdiction. The Court held that the power to impose fines or penalties is ordinarily a judicial function. The Public Service Law ( Act No. 3108 , as amended) only expressly granted the PSC such power in Section 23. The authority cited by the PSC (Section 30) and other penal clauses of the law vest jurisdiction to punish offenders in the courts of competent jurisdiction, not in the PSC. As an administrative body, the PSC can only exercise powers expressly or by necessary implication conferred by statute. Since no such delegation was found, the PSC acted without jurisdiction.
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