G.R. No. L-29236 and L-29247. August 21, 1974.
Radio Communications of the Philippines, Inc., petitioner, vs. Francisco Santiago and Enrique Medina, as Commissioner, Public Service Commission, respondents. (and) Radio Communications of the Philippines, Inc., petitioner, vs. Constancio Jaugan and Enrique Medina, Commissioner, Public Service Commission, respondents.

FACTS

In two consolidated cases, the Public Service Commission (PSC) imposed fines of P200 each on Radio Communications of the Philippines, Inc. (RCPI) for failing to render proper telegraph service. In G.R. No. L-29236, RCPI collected payment for a telegram to Zamboanga City on July 12, 1966, but never transmitted it. In G.R. No. L-29247, RCPI collected payment for a telegram from Dumaguete to Manila on August 1, 1967, but failed to deliver it to the addressee, Commissioner Enrique Medina, until August 15, 1967, causing him unnecessary travel. The PSC, acting on complaints from the customers, found RCPI liable under Section 21 of the Public Service Act and ordered the fines with a warning of potential suspension of its authorized rates for non-payment.

ISSUE

Whether the Public Service Commission had jurisdiction to impose fines on RCPI, a radio company, for its failure to render proper service.

RULING

No. The Supreme Court reversed the orders of the Public Service Commission. The legal logic is anchored on the principle that a public official or agency must locate a statutory grant of power before exercising authority. The Court examined the governing law, Commonwealth Act No. 146 (the Public Service Act). Section 14(e) of the Act explicitly exempts radio companies from the jurisdiction, supervision, and control of the PSC, “except with respect to the fixing of rates.” This exemption is clear and categorical. The power to impose fines under Section 21 of the same Act is a general provision applicable to public services under PSC jurisdiction. Since radio companies are expressly exempted from PSC jurisdiction except for rate-fixing, the general power to fine under Section 21 cannot be invoked against them for service failures. The PSC’s jurisdiction over RCPI is limited solely to the fixing of telegraph rates. Any act beyond this specific grant, such as adjudicating complaints and penalizing service deficiencies, is ultra vires and void. The Court emphasized that absent a clear statutory warrant, the assumption of authority cannot stand. Consequently, the PSC orders imposing fines were issued without jurisdiction and were set aside.