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Globe Wireless vs. Public Service Commission
G.R No. L-27520
A message was addressed to Maria Diaz in Spain which was filed by private respondent, Antonio Arnaiz with Bureau of Telecommunication in Dumaguete city and was transmitted to Bureau of Telecommunications Manila. It was forwarded to the petitioner, Globe Wireless and transmitted it to Empresa Nacional de Telecommunicaciones in Madrid. The latter, however, mislaid said message, resulting in its non-delivery to the addressee. After knowing the fact, Arnaiz filed a complaint relating to the incident with Public Service Commission. After hearings, PSC issued an order finding petitioner "responsible for the inadequate and unsatisfactory service complained of, in violation of the Public Service Act" and ordering it "to pay a fine of P200.00. Through a certiorari, Globe Wireless questioned/challenged the jurisdiction of PSC or the Public Service Commission under Section 21 of the Commonwealth Act 146, which is to discipline and impose a fine over the petitioner.
If PSC has jurisdiction over the matter, the imposition of find and to discipline the petitioner.
Under Section 5 of the Commonwealth Act 146 states that, “The Public Service Commission is hereby given jurisdiction over the grantee only with respect to the rates which the grantee may charge the public subject to international commitments made or adhered to by the Republic of the Philippines.” Under Section 21 of C.A. No. 146, as amended, the Commission was empowered to impose an administrative fine in cases of violation of or failure by a Public service to comply with the terms and conditions of any certificate or any orders, decisions or regulations of the Commission. petitioner operated under a legislative franchise, so there were no terms nor conditions of any certificate issued by the Commission to violate. Neither was there any order, decision or regulation from the Commission applicable to petitioner that the latter had allegedly violated, disobeyed, defied or disregarded. The jurisdiction and powers of administrative agencies are limited to those expressly granted or necessarily implied from those granted in the legislation creating such body; and any order without or beyond such jurisdiction is void and ineffective