GR L 11216; (March, 1916) (Digest)
G.R. No. L-11216; March 6, 1916
COMPAΓIA GENERAL DE TABACOS DE FILIPINAS, petitioner, vs. THE BOARD OF PUBLIC UTILITY COMMISSIONERS, respondent.
FACTS:
The petitioner, CompaΓ±ia General de Tabacos de Filipinas, is a foreign corporation organized under Spanish law, operating as a common carrier by water in the Philippine Islands. On June 7, 1915, the respondent Board of Public Utility Commissioners issued an order requiring the petitioner to show cause why it should not be compelled to file detailed annual reports of its finances and operations, following a specific model form attached to the order. After a hearing, the Board ordered the petitioner to submit such reports annually. The petitioner contested this order before the Board, arguing that Section 16(e) of Act No. 2307 , which authorized the Board to require such reports, constituted an unconstitutional delegation of legislative power if interpreted to grant such authority. The petitioner also contended that the required report was cumbersome and unnecessarily prolix. The case was elevated to the Supreme Court for review under Section 37 of Act No. 2307 .
ISSUE:
Whether Section 16(e) of Act No. 2307 , which empowers the Board of Public Utility Commissioners to require public utilities to furnish annually “a detailed report of finances and operations, in such form and containing such matters as the Board may from time to time by order prescribe,” constitutes an invalid delegation of legislative power.
RULING:
Yes. The Supreme Court declared the provision an unconstitutional delegation of legislative power and set aside the order of the Board.
The Court held that the statutory provision was excessively broad and general. It delegated to the Board the authority to determine the nature, content, form, and all other details of the required reports without providing any guiding principles, rules, or standards from the Legislature. The law did not express the legislative will regarding what specific information the State required for purposes such as taxation, supervision, or control. Instead, it effectively allowed the Board to demand whatever information it wanted, thereby conferring an almost absolute and unguided discretion. This amounted to an abdication of legislative power in favor of the administrative board, which is prohibited. The Court distinguished the case from permissible delegations where the legislature lays down general rules and policies, leaving only administrative details to the implementing body. Consequently, the order of the Board was reversed, and the proceeding was ordered dismissed.
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