G.R. No. 45110 ; November 27, 1936
HOC LIAN HO DRY GOODS CLUB and MELECIO TAN, petitioners-appellants, vs. MANILA ELECTRIC COMPANY, respondent-appellee.

FACTS

Petitioners occupied stalls at the Yangco Market in Manila and had contracts with respondent Manila Electric Company (Meralco) for the supply of electricity to their stalls. These contracts expired on January 31, 1935. Prior to expiration, Meralco, authorized by the Public Service Commission (PSC) to charge a new rate, notified petitioners that beginning February 1, 1935, they must pay under the new rate and execute new contracts based on a 24-hour service basis instead of the previous 12-hour basis. Petitioners refused. Meralco discontinued the electricity supply on February 2, 1935. Petitioners filed a complaint with the PSC, alleging breach of contract and seeking to restrain Meralco from suspending service and imposing the new terms. The PSC dismissed the complaint, and petitioners appealed.

ISSUE

Whether the Public Service Commission erred in dismissing petitioners’ complaint and denying their motions to compel Meralco to continue supplying electricity under the expired contracts.

RULING

No. The Supreme Court affirmed the PSC’s decision. Petitioners conceded their contracts had expired. As a public service operator, Meralco is only obligated to supply electricity to those with valid contracts under conditions authorized by the PSC. Without existing contracts, petitioners cannot compel service unless they execute new contracts complying with authorized conditions. Additionally, the PSC, as an administrative body, lacks judicial power to adjudicate petitioners’ claim that the original contracts were obtained through misrepresentation, deceit, and fraud; such questions fall within the exclusive jurisdiction of ordinary courts. The Court also denied a petition to transmit another PSC case, as it was unnecessary for resolving the appeal.

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