GR L 24165; (August, 1968) (Digest)
G.R. No. L-24165 August 30, 1968
JUAN M. SERRANO, petitioner, vs. PUBLIC SERVICE COMMISSION, CHAMBER OF TAXICAB SERVICES, INC., ADMIRAL TAXI CO., INC., LITA ENTERPRISES COMPANY, INC., SABINO GONZALES, ET AL., respondents.
FACTS
Petitioner Juan M. Serrano filed an application with the Public Service Commission (PSC) for a certificate of public convenience to operate a taxicab service with fifty units. He alleged his qualifications as a Filipino citizen and existing bus operator, financial capacity, and public necessity. His evidence was presented and not rebutted by oppositors. The PSC issued a joint decision on 99 applications, granting certificates to 60 named applicants and summarily stating that the applications not included were “either dismissed for lack of interest or failure to prosecute or denied for failure to qualify.” The decision did not refer individually to Serrano or state the specific reason for the denial/dismissal of his application. Serrano’s motion for reconsideration was denied, prompting this petition for review.
ISSUE
Whether the Public Service Commission committed a reversible error by rendering a decision that failed to state clearly and distinctly the facts and the law upon which the denial or dismissal of the petitioner’s application was based.
RULING
Yes. The Supreme Court set aside the PSC decision insofar as it dismissed or denied Serrano’s application and remanded the case. The Court held that while the constitutional requirement for courts of record to state facts and law in decisions does not apply to the PSC as an administrative tribunal, the PSC is still bound by the fundamental requirements of due process. Citing Ang Tibay v. Court, the Court enumerated cardinal primary rights, including that quasi-judicial tribunals must render decisions such that parties can know the issues involved and the reasons for the decision. The PSC’s summary disposition, without an individual reference to Serrano or a statement of reasons and factual basis for the denial, violated this cardinal primary right. This failure also obstructs the Supreme Court’s power of review, which traditionally defers to PSC factual findings if supported by evidence. The Court deemed it premature to evaluate the sufficiency of Serrano’s evidence, as that evaluation is primarily for the PSC. The case was remanded for the PSC to consider the evidence and render a proper decision stating the facts on which it is based.