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    RCPI v. NTC

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    winter_equinox4
    This case involved a complaint filed against Radio Communications of the Philippines, Inc. (RCPI) for failing to deliver two telegram messages in a timely manner. The National Telecommunications Commission found RCPI liable and imposed a fine. RCPI appealed, arguing that the NTC did not have jurisdiction to impose fines. The Supreme Court agreed, holding that the NTC's powers were limited to those expressly granted by legislation, and no law had granted it the power to impose administrative fines on public utilities for deficient service. Therefore, the NTC overstepped its authority in fining RCPI, so the Court reversed the decision.

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    RCPI v. NTC

    Uploaded by

    winter_equinox4
    1K views1 page
    This case involved a complaint filed against Radio Communications of the Philippines, Inc. (RCPI) for failing to deliver two telegram messages in a timely manner. The National Telecommunications Commission found RCPI liable and imposed a fine. RCPI appealed, arguing that the NTC did not have jurisdiction to impose fines. The Supreme Court agreed, holding that the NTC's powers were limited to those expressly granted by legislation, and no law had granted it the power to impose administrative fines on public utilities for deficient service. Therefore, the NTC overstepped its authority in fining RCPI, so the Court reversed the decision.

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    6. RCPI v. NTC

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    © Attribution Non-Commercial (BY-NC)

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    This case involved a complaint filed against Radio Communications of the Philippines, Inc. (RCPI) for failing to deliver two telegram messages in a timely manner. The National Telecommunications Commission found RCPI liable and imposed a fine. RCPI appealed, arguing that the NTC did not have jurisdiction to impose fines. The Supreme Court agreed, holding that the NTC's powers were limited to those expressly granted by legislation, and no law had granted it the power to impose administrative fines on public utilities for deficient service. Therefore, the NTC overstepped its authority in fining RCPI, so the Court reversed the decision.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    1K views1 page

    RCPI v. NTC

    Uploaded by

    winter_equinox4
    This case involved a complaint filed against Radio Communications of the Philippines, Inc. (RCPI) for failing to deliver two telegram messages in a timely manner. The National Telecommunications Commission found RCPI liable and imposed a fine. RCPI appealed, arguing that the NTC did not have jurisdiction to impose fines. The Supreme Court agreed, holding that the NTC's powers were limited to those expressly granted by legislation, and no law had granted it the power to impose administrative fines on public utilities for deficient service. Therefore, the NTC overstepped its authority in fining RCPI, so the Court reversed the decision.

    Copyright:

    Attribution Non-Commercial (BY-NC)
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    of 1

    Radio Communications of the Philippines, Inc. v.

    National Telecommunications Commission


    G.R. No. 93237 November 6, 1992
    Padilla, J.:

    FACTS: Private respondent Juan A. Alegre's wife, Dr. Jimena Alegre, sent two (2) RUSH telegrams
    through petitioner RCPI's facilities in Taft Ave., Manila at 9:00 in the morning of 17 March 1989 to his
    sister and brother-in-law in Valencia, Bohol and another sister-in-law in Espiritu, Ilocos Norte, with the
    following identical texts: MANONG POLING DIED INTERMENT TUESDAY. Both telegrams did not reach
    their destinations on the expected dates. Thus, private respondent filed a letter-complaint against the
    RCPI with the National Telecommunications Commission (NTC) for poor service, with a request for the
    imposition of the appropriate punitive sanction against the company.

    NTC rendered a decision in favor of private respondent. It found RCPI administratively liable for deficient
    and inadequate service defined under Section 19(a) of C.A. 146 and imposed the penalty of FINE
    payable within thirty (30) days from receipt hereof in the aggregate amount of PHP 1,000.00. RCPI then
    filed a motion for reconsideration which was dismissed. Hence, this petition.

    ISSUE: whether or not the National Telecommunications Communications has jurisdiction to


    administratively impose fines on a telegraph company which fails to render adequate service to a
    consumer.

    HELD: Petitioner RCPI invoked, C.A. 146 Sec. 19(a) which limits the jurisdiction of the Public Service
    Commission (precursor of the NTC) to the fixing of rates. RCPI submits that its position is supported by
    two decided cases.1 The Office of the Solicitor General, on the other hand, claimed that that the cited
    cases are no longer applicable. It averred that the power and authority of the NTC to impose fines is
    incidental to its power to regulate public service utilities and to supervise telecommunications facilities,
    which are now clearly defined in Section 15, Executive Order No. 546 2. NTC also takes the view that its
    power of supervision was broadened by E. O. No. 546, and that this development superseded the ruling
    in RCPI vs. Francisco Santiago and companion cases.

    The Court held however that E. O.546 is couched in general terms. The NTC stepped "into the shoes" of
    the Board of Communications which exercised powers pursuant to the Public Service Act. The power to
    impose fines should therefore be read in the light of the Francisco Santiago case because subsequent
    legislation did not grant additional powers to the Board of Communications. The Board in other words, did
    not possess the power to impose administrative fines on public services rendering deficient service to
    customers, ergo its successor cannot arrogate unto itself such power, in the absence of legislation.

    No substantial change has been brought about by Executive Order No. 546 invoked by the Solicitor
    General's Office to bolster NTC's jurisdiction. The Executive Order is not an explicit grant of power to
    impose administrative fines on public service utilities, including telegraphic agencies, which have failed to
    render adequate service to consumers. Neither has it expanded the coverage of the supervisory and
    regulatory power of the agency. There appears to be no alternative but to reiterate the settled doctrine in
    administrative law that: Too basic in administrative law to need citation of jurisprudence is the rule that
    jurisdiction and powers of administrative agencies, like respondent Commission, 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 . . .

    WHEREFORE, the decision appealed from is REVERSED and SET ASIDE.

    1
    RCPI vs. Francisco Santiago and Enrique Medina, and RCPI vs. Board of Communications
    2
    Functions of the Commission. The Commission shall exercise the following functions:
    b. Establish, prescribe and regulate the areas of operation of particular operators of the public service communications;
    h. Supervise and inspect the operation of radio stations and telecommunications facilities.

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