G.R. No. L-10582; April 30, 1958
CONSTANCIO MANANSALA, petitioner, vs. ANTONIO HERAS, MD TRANSIT and TAXI CO., INC., CAM TRANSIT, FORTUNATO F. HALILI, and PUBLIC SERVICE COMMISSION, respondents.

FACTS

Petitioner Constancio Manansala, holder of a 5-year certificate of public convenience to operate three (3) jitneys (TPU) on specified routes in Manila, filed an application with the Public Service Commission (PSC) to register one (1) additional jitney unit as a reserve. His purpose was to use this reserve unit only when any of his three regular units was under repair to ensure continuity of service. However, his certificate contained a condition that during its lifetime, he “shall not ask for extension of line or increase of equipment or trips, nor substitution of equipment.” The PSC denied his application. In its decision, the PSC found that: (1) the cessation of operation due to equipment repair would not harm the public as there were sufficient means of transportation in Manila and its nearby areas; (2) jitney operators with reserve equipment often used them for illegal regular operations, making detection difficult; and (3) it was announcing a new policy to not authorize any reserve equipment for TPU operators in specified cities and towns who are not operating under regular 25-year certificates. Manansala filed a petition for review of this decision.

ISSUE

Whether the Public Service Commission committed a reversible error in denying petitioner’s application to register a reserve jitney unit.

RULING

The Supreme Court affirmed the decision of the Public Service Commission, finding no merit in petitioner’s arguments. The Court held:
1. The denial did not violate the constitutional guarantee of equal protection of the law. TPU operators with short-term (5-year) certificates cannot claim privileges equal to those holding 25-year certificates, as the latter’s certificates are of a different nature. Granting reserves to short-term operators might later be used as a ground to extend the limited period of their certificates.
2. The PSC’s finding that there were more than sufficient transportation units in Manila was supported by evidence, including testimony from a competent police officer and petitioner’s own admission that no complaints were registered when his units were under repair, indicating public convenience was not affected.
3. The denial of a reserve unit did not make the petitioner unable to render adequate service, as the PSC had found that too many certificates had been issued, making the failure of some operators to provide continuous service not necessarily an inconvenience to the public. The policy adopted by the PSC was justified by the circumstances.
4. No hearing on the motion for reconsideration was required for due process, as the movant can set forth all grounds in the written motion itself. An actual hearing is not considered essential.
The decision appealed from was affirmed, with costs against the petitioner.