G.R. No. L-19558; November 29, 1963
LA MALLORCA and PAMPANGA BUS COMPANY, petitioners, vs. CIRILO D. MENDIOLA, respondent.

FACTS

Petitioners La Mallorca and Pampanga Bus Company sought the setting aside of a Public Service Commission (PSC) decision and a remand of the case for a new trial. This motion was grounded on the loss of their Exhibits D, D-1, D-1-a, D-1-b, D-1-c, and D-1-d while in the PSC’s custody, which they claimed rendered reconstitution impossible. These exhibits were observation reports detailing the operation of vehicles on the Guagua-San Fernando line, including plate numbers, passenger loads, and directions, which petitioners had submitted to rebut the application of respondent Cirilo D. Mendiola for a certificate of public convenience to operate on the same line.
The PSC had granted Mendiola’s application, finding from the evidence that existing services were insufficient for passenger demand and that Mendiola was financially capable. Petitioners argued that the loss of their crucial rebuttal exhibits deprived them of a fair consideration of their case, necessitating a new trial to present the lost evidence anew.

ISSUE

Whether the loss of the petitioners’ exhibits while in the custody of the Public Service Commission warrants the setting aside of its decision and a remand of the case for a new trial.

RULING

The Supreme Court denied the petitioners’ motion. The Court’s resolution was anchored on the limited scope of its review over decisions of administrative bodies like the PSC. The established doctrine is that the Supreme Court does not reweigh conflicting evidence or substitute its own factual conclusions for those of the Commission. Its sole function is to determine whether there was substantial evidence before the Commission to reasonably support its decision.
The Court noted that the lost exhibits were petitioners’ rebuttal evidence. Critically, there was no proof that the PSC failed to consider these exhibits when it rendered its decision. The PSC’s decision explicitly stated it was based on the “mass of evidence,” implying a review of all submitted proofs. The Court emphasized that the validity of the PSC’s findings primarily depended on the character of the applicant’s (Mendiola’s) evidence, which remained intact and unchallenged as to its loss. Since the petitioners failed to demonstrate that the PSC’s decision lacked reasonable evidentiary support from the record that remained, the loss of their exhibits did not justify nullifying the proceedings. The Court ordered the petitioners to proceed with the appeal by filing their brief.