GR 46484; (September, 1939) (Digest)
G.R. No. 46484 ; September 30, 1939
SANTIAGO SAMBRANO, petitioner, vs. RED LINE TRANSPORTATION COMPANY, INC., and NORTHERN LUZON TRANSPORTATION COMPANY, INC., respondents.
FACTS
The Public Service Commission (PSC) approved the sale of a bus line from Camalaniugan to Pamplona in Cagayan Valley, originally granted to Interprovincial Transportation Company, then sold to Red Line Transportation Co., Inc., and subsequently sold to Northern Luzon Transportation Co., Inc. The PSC ordered a hearing on the approval of the sale, with due publication as required by law. Petitioner Santiago Sambrano filed an opposition (“Manifestacion”) only after the hearing had commenced, opposing the sale and an extension request by Northern Luzon. The PSC reopened the case for hearing, but Sambrano failed to appear on the rescheduled dates. The PSC then overruled his opposition and approved the sale. Sambrano petitioned for review, alleging the PSC erred in accepting and approving the sale.
ISSUE
Whether the petitioner has the legal standing or right of action to institute the proceeding for review of the PSC’s decision.
RULING
No. The Supreme Court affirmed the PSC’s decision, holding that the petitioner lacked the requisite legal standing. Under Section 36 of Commonwealth Act No. 146 , only a “person or public service affected” by a PSC decision may seek review. The petitioner failed to demonstrate a direct, substantial interest susceptible of valuation. His mere status as a Filipino citizen and potential user of the bus line is insufficient, as it constitutes only a general interest common to the public. His failure to prosecute his opposition before the PSC by not appearing at the hearings further indicated a lack of real interest. The Court cited the doctrine that a party must show having sustained or being in immediate danger of sustaining a specific injury, not merely a general public interest. The PSC’s approval of the sale, made after proper publication and without valid objection from any real party in interest, was thus upheld.
AI Generated by Armztrong.