G.R. No. L-43653 and G.R. No. L-45378, November 29, 1977
RADIO COMMUNICATIONS OF THE PHILIPPINES, INC. (RCPI), petitioner, vs. BOARD OF COMMUNICATIONS and DIEGO MORALES, respondents. (Consolidated with RADIO COMMUNICATIONS OF THE PHILIPPINES, INC. (RCPI), petitioner, vs. BOARD OF COMMUNICATIONS and PACIFICO INNOCENCIO, respondents.)

FACTS

These consolidated petitions involve two complaints filed with the respondent Board of Communications against petitioner RCPI. In the first case, respondent Diego Morales alleged that a telegram informing him of his wife’s death, sent via RCPI from Isabela to Manila in October 1974, never reached him, causing him inconvenience and additional travel expenses. RCPI explained that the message became unreadable due to intermittent radio signals during relay. In the second case, respondent Pacifico Innocencio claimed that a July 1975 telegram from Tarlac, sent to inform him of his father’s death, was not delivered to him in Laguna, nor was the sender notified of the non-delivery. He asserted he suffered mental anguish and personal inconvenience from missing the interment.
After hearings, the Board of Communications found RCPI’s service inadequate and unsatisfactory in both instances. It imposed upon RCPI a disciplinary fine of Two Hundred Pesos (P200) in each case, pursuant to Section 21 of Commonwealth Act No. 146 , as amended (The Public Service Act).

ISSUE

Whether the Board of Communications has jurisdiction to entertain complaints for damages arising from the alleged failure of a telegraph company to transmit or deliver telegrams.

RULING

The Supreme Court ruled that the Board of Communications lacks jurisdiction over such claims. The Court emphasized that the Board, as the successor of the Public Service Commission (PSC), is an administrative body with powers limited to those expressly or by necessary implication conferred by statute. Its functions are primarily regulatory and administrative, such as issuing certificates of public convenience and fixing rates. The power to impose fines under Section 21 of the Public Service Act is specifically tied to violations of the terms and conditions of a certificate of public convenience or of the Commission’s own orders, decisions, or regulations.
The complaints filed by Morales and Innocencio did not allege any violation of RCPI’s certificate or of a Board order. Instead, they essentially alleged a breach of contractual obligation arising from negligence, or possibly a quasi-delict, which are causes of action governed by the Civil Code. Claims for damages stemming from such personal injuries, inconvenience, or mental anguish are matters within the original jurisdiction of regular courts, not an administrative board. The Court cited its prior ruling in Santiago v. RCPI, which held that the PSC (and by extension, the Board) lacked authority to impose fines for negligence or misfeasance by a radio company, as it was not vested with such adjudicatory power over claims for damages. Consequently, the decisions of the Board of Communications were reversed and set aside for lack of jurisdiction.