G.R. No. 41061 ; February 23, 1934
MOISES AMPIL, petitioner, vs. THE PUBLIC SERVICE COMMISSION, respondent.

FACTS

Petitioner Moises Ampil, an operator of one auto-calesa in Manila, applied with the Public Service Commission (PSC) to increase his equipment by thirty additional auto-calesas. The PSC granted the application but imposed a condition limiting the number of persons each auto-calesa could carry to five (including the driver), or to three passengers if the petitioner opted to employ both a driver and a conductor. Dissatisfied, Ampil sought reconsideration, which the PSC denied. He then filed this action for certiorari, arguing that the PSC exceeded its jurisdiction by limiting passenger capacity below the vehicle’s actual capacity.

ISSUE

Whether the Public Service Commission acted within its jurisdiction in imposing a condition limiting the passenger capacity of the auto-calesas below their actual capacity.

RULING

Yes, the Public Service Commission acted within its jurisdiction. The Court held that the PSC’s power to impose such conditions is distinct from the Bureau of Public Works’ authority to fix vehicle capacity for registration fee purposes. Based on public hearings and investigations, the PSC determined that allowing auto-calesas to operate at full capacity (7-8 passengers) would lead to ruinous and unlawful competition with existing transportation utilities. The condition was a reasonable regulatory measure to ensure auto-calesas operated as a cheap form of transportation (competing with horse-drawn calesas) rather than as jitneys engaging in cut-throat competition. The Court found the condition non-arbitrary, based on experience, and within the PSC’s authority to attach limitations to a certificate of public convenience. The petition was denied.

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