G.R. No. L-31056 August 4, 1988
Lucila O. Manzanal, petitioner, vs. Mauro A. Ausejo and Public Service Commission, respondents.

FACTS

The case originated from a complaint by Mauro Ausejo, who alleged he was held up on March 13, 1966. He claimed the perpetrators escaped using a taxicab with plate number “6100,” which he implicated in an affidavit. Based on this, the Public Service Commission (PSC) issued a show-cause order against petitioner Lucila Manzanal, the operator of a taxicab service, alleging failure to render safe and adequate service by employing a driver with criminal tendencies, in violation of the Public Service Act. At the trial, Ausejo and his companion testified about the hold-up and described the taxi, though their descriptions of its color slightly differed. Manzanal presented documentary evidence to dispute that the involved vehicle was hers, showing her taxi’s distinct color scheme and that license plates for that period were of a different color.
The PSC, in an order dated June 30, 1967, cancelled Manzanal’s certificate of public convenience. The Commission found the charges proven, noting the witnesses had no motive to testify falsely, that they focused on the plate number, and that Manzanal’s conduct gave the impression of protecting the driver. Her motions for reconsideration were denied, prompting this petition for review.

ISSUE

Whether the Public Service Commission acted with grave abuse of discretion in cancelling Manzanal’s certificate of public convenience based on the evidence presented.

RULING

The Supreme Court granted the petition and reversed the PSC’s orders. The legal logic centered on the absence of substantial evidence to support the cancellation and a misapplication of the legal grounds for revocation. The Court clarified that under Section 16(m) of the Public Service Act, a certificate can only be cancelled for a willful and contumacious violation of the Commission’s orders or the law. The mere alleged involvement of a taxicab in a criminal incident, without proof of the operator’s knowledge or complicity, does not constitute such a violation. The PSC’s finding that Manzanal failed to render safe service by employing a driver with criminal tendencies was baseless, as there was no evidence presented about the driver’s alleged criminal record or character.
Furthermore, the Court found the PSC’s factual conclusions unsupported. The claim that Manzanal shielded her driver was erroneous, as the record showed the driver was present at hearings until his death, and Manzanal explained her lack of personal knowledge about the incident. The discrepancies in the witnesses’ descriptions and the documentary evidence contradicting their account were not adequately considered. The Supreme Court emphasized that while it generally respects the PSC’s factual findings, it can review them when, as here, they are not supported by substantial evidence. The cancellation was therefore invalid, as the requisite willful violation was not established.