G.R. No. L-29185 September 24, 1985
GAVINO T. VAGILIDAD, petitioner, vs. MANUEL M. MAS and THE PUBLIC SERVICE COMMISSION, respondents.

FACTS

Respondent Manuel M. Mas filed a complaint before the Public Service Commission (PSC) against petitioner Gavino T. Vagilidad, a jeepney operator. The complaint alleged that Vagilidad was operating four jeepneys under the “kabit” system and, more critically, that these vehicles were illegally plying the Sibalom-San Jose via Odiong route in Antique. This specific route was covered by Mas’s own certificate of public convenience, not by any of Vagilidad’s authorized lines. Following the complaint, a PSC inspector investigated and apprehended three of Vagilidad’s jeepneys (PUJ-10561, PUJ-10606, and PUJ-10694) for operating outside their authorized lines on the contested route, with additional violations for overloading and trip-cutting.
The PSC set the case for hearing. Despite notice, only the complainant appeared, leading the Commission to declare Vagilidad in default and receive evidence ex parte. Vagilidad later moved to lift the default order, which was granted, allowing for a subsequent hearing. After proceedings, the PSC found Vagilidad guilty of violating the terms of his certificates of public convenience.

ISSUE

Whether the Supreme Court can review and overturn the factual findings of the Public Service Commission that petitioner Vagilidad operated his vehicles outside his authorized route, thereby violating his certificates of public convenience.

RULING

The Supreme Court dismissed the petition, upholding the orders of the Public Service Commission. The Court’s ruling is anchored on the well-established doctrine of limited appellate review over administrative agencies’ factual determinations. Petitioner Vagilidad raised issues that were fundamentally factual, challenging the sufficiency of the evidence that proved his vehicles were operating on the unauthorized Sibalom-San Jose via Odiong route, a route legally franchised to respondent Mas.
The Court explicitly declined to re-examine the evidence or substitute its judgment for that of the PSC on questions of fact. It reiterated the settled rule that where a petition for review merely disputes the sufficiency of the evidence, the administrative body’s findings are conclusive if supported by substantial evidence. The PSC’s findings, based on the inspector’s report and testimony detailing the specific apprehensions and the mismatch between the operated route and Vagilidad’s authorized lines, were deemed factual and binding. The Court emphasized that its role is not to re-evaluate the credibility of witnesses or the preponderance of proof but to determine if the PSC acted without or in excess of its jurisdiction or with grave abuse of discretion. No such jurisdictional flaw or abuse was found. The fines imposed were a valid exercise of the PSC’s regulatory power to enforce compliance with certificates of public convenience.