G.R. No. L-32097-98 March 30, 1979
CITY OF LAOAG and MUNICIPALITY OF SAN NICOLAS, ILOCOS NORTE, petitioners, vs. THE PUBLIC SERVICE COMMISSION and ILOCOS NORTE ELECTRIC COMPANY, INC., respondents.

FACTS

The petitioners, City of Laoag and Municipality of San Nicolas, sought a review of a Public Service Commission (PSC) decision authorizing Ilocos Norte Electric Company (INELCO) to implement specific rate reductions. For years, consumers and local governments protested INELCO’s allegedly inefficient service, low voltage, constant brownouts, and high rates. Following public hearings, INELCO reduced its general rates by 5% effective January 1, 1960, with a 20% reduction for municipal street lighting. The PSC later ordered this 5% reduction to retroact to August 1959, but INELCO sought reconsideration. During subsequent proceedings, the PSC directed the parties to reach an amicable settlement. INELCO alleged an agreement with the local mayors for an additional 3% voluntary reduction, effective January 1, 1963, totaling an 8% reduction. The petitioners contested this agreement, arguing it lacked approval from their respective municipal councils, and instead submitted their own proposed rate schedules via a council resolution.

ISSUE

The primary issue is whether the petitioners’ appeal from the PSC decision was filed on time, thereby vesting the Supreme Court with jurisdiction to review the merits of the rate authorization.

RULING

The Supreme Court dismissed the petition, ruling it was filed out of time and the PSC decision had become final and executory. The legal logic centers on strict compliance with procedural periods for appeals from quasi-judicial bodies. The PSC rendered its decision on April 17, 1968. The petitioners’ counsel obtained a copy of the decision from the PSC secretary on May 30, 1968, which the Court deemed a substantial compliance with the notice requirement. Under the Public Service Act, a motion for reconsideration must be filed within 15 days from notice. The petitioners filed their motion on June 18, 1968, which was 19 days from May 30, 1968, and thus filed out of time. Consequently, the PSC should have denied the motion as tardy. Furthermore, an appeal via a petition for review to the Supreme Court must be filed within 30 days from notice. No such petition was filed within 30 days of May 30, 1968. The decision therefore became final on June 29, 1968. The perfection of an appeal within the statutory period is jurisdictional; failure to comply renders the decision final by operation of law. Since the petitioners failed to timely appeal, the Supreme Court lacked jurisdiction to review the substantive aspects of the PSC’s order on rate reductions.