Radio Communication of the Philippines, Inc. (RCPI) vs.

Santiago

FACTS:

RCPI filed a petition before the Court to challenge both the orders in RCPI v. Santiago and RCPI v.
Jaugan, imposing a P200.00 fine pursuant to Section 21 of Public Service Act.

Both cases stemmed out from the failure of RCPI to transmit the telegrams to its rightful recipient
even after collecting the payment from the complainants. Complaints of Mr. Santiago and Mr. Jaugan
were filed before the Public Service Commission (PSC). Acting on both complaints, the PSC ordered
RCPI to pay a fine of P200 for each case, as a consequence of their failure to render the services
required of them.

ISSUE:

Whether or not the PSC has the jurisdiction to act on the complaints against RCPI and penalize it with
a fine

RULING:

No. Under the doctrine laid down in the Villegas v. Subido case, the government itself is merely an
agency through which the will of the State is expressed and enforced. Its officers are likewise agents
entrusted with the responsibility of discharging its functions. There must be a delegation of such
authority, either express or implied. Absence of a valid grant of authority makes them devoid of power.

Here, PSC was not vested with the authority to impose fines over RCPI. The only power of PSC over
radio companies was to fix the rates pursuant to Section 14 of Public Service Act. The PSC exceeded
its authority, thus, the challenged order was reversed and set aside.