Law School Noob: [CASE DIGEST] MANILA ELECTRIC COMPANY v. PASAY TRANSPORTATION COMPANY, INC., et al. (G.R. No. L-37878)

Wednesday, December 30, 2020

[CASE DIGEST] MANILA ELECTRIC COMPANY v. PASAY TRANSPORTATION COMPANY, INC., et al. (G.R. No. L-37878)

November 25, 1932

Ponente: Malcolm, J.

FACTS

In its petition filed before the Supreme Court, Manila Electric Company (MEC) asked members of the Supreme Court to convene as arbitrators in order to determine the compensation to be paid to MEC by transportation companies that use the MEC-owned Pasig bridge.

MEC cited Sec. 11 of Act No. 1446, the law which granted franchise to MEC to operate an electric railway and operate a power system in Manila, as its legal basis.

Said provision provides that: "Whenever any franchise or right of way is granted to any other person or corporation, now or hereafter in existence, over portions of the lines and tracks of the grantee herein, the terms on which said other person or corporation shall use such right of way, and the compensation to be paid to the grantee herein by such other person or corporation for said use, shall be fixed by the members of the Supreme Court, sitting as a board of arbitrators, the decision of a majority of whom shall be final."

Essentially, the subject provision requires SC justices, who are exercising judicial functions, to also perform administrative or quasi judicial functions.

RULING

May members of the Supreme Court convene as a board of arbitrators to determine the rate MEC may charge to transportation companies that use MEC's properties? -- NO.

The determination of rates following arbitration proceedings is not a judicial function, but rather an administrative or quasi-judicial function over which the SC does not exercise jurisdiction.

Otherwise, it would result in an absurd situation where members of the SC who have made an arbitration ruling will be the same people to decide on such ruling should the same be elevated and questioned before the Supreme Court.

In his ruling, Justice Malcolm underscored that: "The Supreme Court of the Philippine Islands represents one of the three divisions of power in our government. It is judicial power and judicial power only which is exercised by the Supreme Court. Just as the Supreme Court, as the guardian of constitutional rights, should not sanction usurpations by any other department of the government, so should it as strictly confine its own sphere of influence to the powers expressly or by implication conferred on it by the Organic Act. The Supreme Court and its members should not and cannot be required to exercise any power or to perform any trust or to assume any duty not pertaining to or connected with the administering of judicial functions."

The SC held that because the power it has is exclusively judicial, it would be improper and illegal for the members of the Supreme Court, sitting as a board of arbitrators, the decision of a majority of whom shall be final, to act on the petition of the Manila Electric Company.

Effectively, Sec. 11 of Act No. 1446 is unconstitutional for being inconsistent with the Organic Act. Congress cannot require or authorize the SC to exercise any other jurisdiction or power, or perform any other duty, apart from purely judicial functions.

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