G.R. No. L-325. October 31, 1947.
RAMON L. CORPUS, petitioner, vs. THE PUBLIC SERVICE COMMISSION, respondent.

FACTS

On January 12, 1946, the Public Service Commission granted petitioner Ramon L. Corpus a certificate of public convenience to operate an auto-truck service for passengers and freight on specified lines. The commission, however, provided that the certificate would be valid only “until December 31, 1947.” The commission also reserved the right to alter or modify the conditions of the certificate to adjust operations to changing conditions, noting the service was authorized during a state of emergency. Although petitioner had agreed in his application to accept a period fixed by the commission and manifested conformity during his testimony, he sought modification of this time limit from the Supreme Court. The evidence showed petitioner would use several second-hand vehicles, models from 1935 to 1938, which he bought in July 1945, and whose prior use was unknown. Oppositors to the application, prior operators, argued for protection of their rights, but the commission found public necessity and convenience demanded approval of the application, as oppositors were rendering only a small fraction or none of their authorized service.

ISSUE

Whether the Public Service Commission committed an abuse of discretion or exceeded the bounds of reasonable judgment in fixing the validity of the certificate only until December 31, 1947.

RULING

The Supreme Court affirmed the decision of the Public Service Commission. The court held that the commission has the authority to fix a time limit, with a maximum period of 50 years under the law. The court found no abuse of discretion. The provisional character of the certificate, granted during a state of emergency, logically supported a short period. The age and condition of petitioner’s second-hand vehicles, which had been in use years before the war and likely suffered from inadequate repairs during the Japanese occupation, justified the time limit. The court reasoned that considering the heavy use and rough handling typical in public service, the vehicles might not remain safe or serviceable for long, and the limit was not unreasonable. The commission’s reservation of the right to modify conditions was seen as a wise measure to ensure public safety. No evidence was presented to show the commission acted arbitrarily. The dissenting opinion argued the two-year limit was unjust, stifled small new operators, and failed to address the ongoing transportation crisis, advocating for a longer, equitable period to allow recovery of investment. The majority, however, upheld the commission’s decision.