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99 - RCPI Vs Board of Communications

The Board of Communications ruled that the telecommunications company RCPI provided inadequate service after two individuals did not receive telegram messages informing them of family deaths. RCPI argued the Board did not have jurisdiction over complaints involving contractual breach or negligence, which should be addressed in courts. The Supreme Court ruled that the Board's authority was limited to issues regarding certificates of public convenience and not complaints unrelated to management of transmission facilities. The Court found the Board exceeded its authority in fining RCPI and that complaints seeking damages should be addressed in courts instead.

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Maria Lourdes Dator
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108 views1 page

99 - RCPI Vs Board of Communications

The Board of Communications ruled that the telecommunications company RCPI provided inadequate service after two individuals did not receive telegram messages informing them of family deaths. RCPI argued the Board did not have jurisdiction over complaints involving contractual breach or negligence, which should be addressed in courts. The Supreme Court ruled that the Board's authority was limited to issues regarding certificates of public convenience and not complaints unrelated to management of transmission facilities. The Court found the Board exceeded its authority in fining RCPI and that complaints seeking damages should be addressed in courts instead.

Uploaded by

Maria Lourdes Dator
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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RCPI v Board of Communications (1977)

Doctrine: The functions of the Public Service Commission and its successor-in-interest, the
Board of Communications, are limited and administrative in nature and it has only jurisdiction
and power as are expressly or by necessary implication conferred upon it by statute.

Summary: Two consolidated petitions for review by certiorari of the decisions of the Board of
Communications involving the same issue. (1) Morales claims that while he was in Manila his
daughter sent him a telegram informing him of the death of his wife. The telegram sent thru the
petitioner RCPI however never reached him. (2) Innocencio claims that his sister sent a
telegram thru the facilities of the petitioner RCPI informing him about the death of their father.
The telegram was never received and the sender had not been notified about its non-delivery.
Because of the failure of the RCPI to transmit said telegram to them and the attendant anguish
and inconvenience caused, both respondents pray for damages. After hearing, the respondent
Board in both cases held that the service rendered by petitioner was inadequate and
unsatisfactory and imposed upon the petitioner in each case a disciplinary fine of P200.
Petitioner argues that respondent Board has no jurisdiction to entertain and take cognizance of
complaints for injury caused by breach of contractual obligation arising from negligence
covered by Article 1170 of the Civil Code and injury caused by quasi delict or tort liability under
Article 2176 of the Civil Code which according to it should be ventilated in the proper courts of
justice and not in the Board of Communications.

Issue: W/N Board of Communications has jurisdiction.

Ruling: NO. The Public Service Commission and its successor in interest, the Board of
Communications, "being a creature of the legislature and not a court, can exercise only such
jurisdiction and powers as are expressly or by necessary implication, conferred upon it by
statute". The functions of the Public Service Commission are limited and administrative in
nature and it has only jurisdiction and power as are expressly or by necessary implication
conferred upon it by statute. As successor in interest of the Public Service Commission, the
Board of Communications exercises the same powers, jurisdiction and functions as that
provided for in the Public Service Act for the Public Service Commission. One of these powers is
to issue certificate of public convenience. But this power to issue certificate of public
convenience does not carry with it the power of supervision and control over matters not
related to the issuance of certificate of public convenience. But even assuming that the
respondent Board of Communications has the power or jurisdiction over petitioner in the
exercise of its supervision to insure adequate public service, petitioner cannot be subjected to
payment of fine under Section 21 of the Public Service Act, because this provision of the law
subjects to a fine every public service that violates or fails to comply with the terms and
conditions of any certificate or any orders, decisions or regulations of the Commission. In the
two cases before the SC, the charge does not relate to the management of the facilities and
system of transmission of messages by petitioner in accordance with its certificate of public
convenience. The proper forum for complainants to ventilate their grievances for possible
recovery of damages against petitioner should be in the courts and not in the respondent Board
of Communications. Much less can it impose the disciplinary fine of P200 upon the petitioner.

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