Comm2 Reviewer — Part III-B: Authority to Operate; CPC

PART 1 — SYLLABUS

1. Coverage Map

2. Learning Objectives

1. Recite the Sec. 15 prohibition cold and state who must hold a certificate before operating.
2. Distinguish a legislative franchise from a certificate of public convenience and state when each is required.
3. Explain how Congress delegates licensing power to agencies and to local government units and name the limits of each delegation.
4. Run the issuance checklist in order: citizenship, financial and technical capability, and promotion of the public interest in a proper and suitable manner.
5. State the prior operator rule with its limit and apply the public-interest primacy that defeats it.
6. Distinguish provisional authority from a final certificate and state the conditions and duration of each.
7. Run the transfer checklist: which transactions need prior approval, the forty percent stock-transfer ceiling, and the sixty percent alien-transfer floor.
8. Draft a complete answer on franchise necessity, issuance, transfer validity, or revocation under time.

3. Authority Inventory

A. Cases

B. Laws and Rules

4. Three-Pass Study Plan

Why this order: the examiner grades provision-first answers, so the authority filter comes before doctrine. Then confusion pairs win marks because Part III-B questions are built to punish merged characterizations of franchises, certificates, and transfers.

5. Syllabus Self-Check

1. Recite the Sec. 15 prohibition and state the finding the Commission must make before issuing any certificate. (§1)
2. A radio company holds a legislative franchise and operates new telephone services without any certificate. May the NTC stop the new services. (§1)
3. A domestic airline holds no congressional franchise and seeks a CPCN from the CAB. Must the Board dismiss for want of jurisdiction. (§1)
4. A port authority contracts out terminal operation with presidential approval and no statute grants the contractor a franchise. Must Congress still grant one. (§1)
5. A broadcast operator holds an NTC permit but never secured a congressional franchise. May it stay on the air. (§1)
6. A municipality grants an electric franchise to an unincorporated group that incorporates a month later. Is the grant void. (§1)
7. An applicant shows Filipino citizenship and rolling stock while the incumbent claims ruinous competition. What must the Commission still find before granting. (§2)
8. An incumbent invokes the prior operator rule against a newcomer on a route with unserved passengers. Does the rule bar the grant. (§2)
9. A telecom incumbent claims exclusive rights over Manila and Navotas under its provisional authority. May the NTC authorize a second carrier there. (§2)
10. A provisional authority holder operates beyond eighteen months while the main case pends. Has the authority ripened into a final certificate. (§2)
11. A public service sells forty-five percent of its subscribed capital to one buyer without asking the Commission. Is the sale valid. (§3)
12. A utility sells ten percent of its stock to an alien and Filipino holdings fall to fifty-five percent. What follows for the sale and the certificate. (§3)
13. A certificate holder ignores voltage directives since 1954 and cures nothing after hearings. Must the Commission impose only a fine. (§3)
14. A creditor attaches the certificates of a bus operator and buys them at auction. May the Commission approve transfer to the creditor over a later private buyer. (§3)

PART 2 — BOOK + AUTHORITY REVIEWER

0. One-Page Outline

Framing questions for every problem: what authority is tested (franchise, certificate, provisional grant, or transfer approval). Which provision supplies each element. What exception, delegation, or competition fact defeats it. What remedy and what tribunal controls the outcome.

Mnemonic for the three sections: Approve First, Issue Fairly, Transfer Formally (A-F-T). Numbers: 15-16-20 (prohibition, issuance, transfer), 40-60 (stock ceilings and floors), 50 (maximum years).

1. Acts Requiring Approval; Legislative Franchise vs CPC; When Franchise Necessary; CPC; LGU Delegation

“With the exception of those enumerated in the preceding section, no public service shall operate in the Philippines without possessing a valid and subsisting certificate from the Public Service Commission known as ‘certificate of public convenience,’ or ‘certificate of public convenience and necessity,’ as the case may be, to the effect that the operation of said service and the authorization to do business will promote the public interests in a proper and suitable manner.”

“The Commission shall have power, upon proper notice and hearing in accordance with the rules and provisions of this Act, subject to the limitations and exceptions mentioned and saving provisions to the contrary: (a) To issue certificates which shall be known as certificates of public convenience, authorizing the operation of public service within the Philippines whenever the Commission finds that the operation of the public service proposed and the authorization to do business will promote the public interest in a proper and suitable manner. Provided, That thereafter, certificates of public convenience and certificates of public convenience and necessity will be granted only to citizens of the Philippines or of the United States or to corporations, co-partnerships, associations or joint-stock companies constituted and organized under the laws of the Philippines; Provided, That sixty per centum of the stock or paid-up capital of any such corporations, co-partnership, association or joint-stock company must belong entirely to citizens of the Philippines or of the United States: Provided, further, That no such certificates shall be issued for a period of more than fifty years.”

“To approve, subject to constitutional limitations any franchise or privilege granted under the provisions of Act No. Six Hundred and Sixty-seven, as amended by Act No. One Thousand and twenty-two, by any political subdivision of the Philippines when, in the judgment of the Commission, such franchise or privilege will properly conserve the public interests, and the Commission shall in so approving impose such conditions as to construction, equipment, maintenance, service, or operation as the public interests and convenience may reasonably require, and to issue certificates of public convenience and necessity when such is required or provided by any law or franchise.”

A legislative franchise comes from the sovereign through Congress, while a certificate comes from the regulator through delegated police power. A franchise answers whether the State opened the activity, while a certificate answers whether this operator may perform it. Absence of a franchise goes to the merits of issuance, while absence of jurisdiction goes to the power to hear at all.

Case: PAL v. CAB, G.R. No. 119528, March 26, 1997

Facts: GrandAir applied to the CAB for a certificate to operate domestic air services, PAL opposed for want of a prior congressional franchise and assailed the three-month temporary operating permit the Board issued before reception of evidence.

Issue: The issue was whether the CAB could hear the application and issue a certificate or temporary permit without a legislative franchise first obtained from Congress.

Held: The Court held that it could, because R.A. No. 776 expressly empowers the Board to issue certificates and temporary permits, the delegation is circumscribed by policy, citizenship, fitness, and procedure standards, and the want of a franchise affects only ultimate issuance and never the jurisdiction to hear.

Doctrine: Congress may validly delegate the power to authorize operation of certain utilities to administrative agencies, a legislative franchise is not indispensable where the statute supplies the licensing scheme, and the Board may grant a temporary permit even before presentation of evidence.

Case: RCPI v. NTC, G.R. No. L-68729, May 29, 1987

Facts: RCPI operated radio telephone services in three areas under its 1957 legislative franchise, a rival received NTC authority for the same areas, and the NTC ordered RCPI to cease operations conducted without any certificate.

Issue: The issue was whether a legislative franchise alone authorizes operation without a certificate and whether a prior franchisee blocks later authority over the same area.

Held: The Court held that it does not, because reorganization laws removed the old radio exemption and imposed the certificate requirement, the franchise itself demanded prior allotment and licensing, and no franchise is ever exclusive so prior operations yield to a later grant made for the public interest.

Doctrine: A franchise is a mere privilege subject to police-power regulation, it cannot be exclusive in character, and an existing operator has no insuperable right against later authority issued over the same area.

Case: Albano v. Reyes, G.R. No. 83551, July 11, 1989

Facts: The PPA bid out the development, management, and operation of the Manila container terminal, awarded the contract to ICTSI with presidential approval, and a legislator claimed that only a congressional franchise could authorize the private operation of the port.

Issue: The issue was whether every public-utility operation needs a franchise specially granted by Congress despite a statute vesting licensing power in an executive agency.

Held: The Court held that none was needed, because E.O. No. 30 tasked the PPA with the terminal and P.D. No. 857 lets it operate by itself or by contract, so the contract with presidential approval substantially complied with the law as the necessary authorization.

Doctrine: Congress may delegate licensing power to executive agencies, a statute may vest an agency with authority to license a class of utilities, and the valid exercise of that delegated power needs no separate congressional franchise.

Case: ACWS v. NTC, G.R. No. 144109, February 17, 2003

Facts: ACWS operated television Channel 25 under NTC permits after its franchise lapsed, filed a late franchise bill it never pursued, missed the memorandum deadline to secure a franchise, and faced recall of its frequency with denial of its renewal application.

Issue: The issue was whether a congressional franchise remains a condition sine qua non for broadcast operation despite later laws vesting certificate and licensing powers in the NTC.

Held: The Court held that it does, because Act No. 3846 exacts a franchise for radio and television, neither P.D. No. 576-A nor E.O. No. 546 expressly or impliedly repealed the exaction, and the franchise and the certificate are distinct forms of authority that coexist.

Doctrine: A congressional franchise is indispensable where the governing law exacts one, a certificate never dispenses with a required franchise, an erroneous permit never estops the government, and recall needs due process through notice, hearing, and substantial evidence.

Q: A domestic airline with no congressional franchise applies to the CAB for a certificate while the statute lays down policy, citizenship, fitness, and procedure standards. An incumbent insists the Board must dismiss for want of jurisdiction. Must the Board dismiss.

A: No, because R.A. No. 776 validly delegates domestic air-transport licensing to the Board and a franchise is not indispensable there. The law empowers the Board to issue certificates and temporary permits upon the stated standards, and the ruling in PAL v. CAB (G.R. No. 119528, 1997) holds that absence of a franchise goes to the merits of issuance and never to the jurisdiction to hear. The Board therefore hears the application and decides the certificate on fitness and public convenience.

Q: A television operator holds a subsisting NTC permit but never obtained the congressional franchise that the radio law exacts. The NTC recalls its frequency after due hearing. Is the recall valid.

A: Yes. The governing broadcast law makes the congressional franchise a condition sine qua non, and later laws vesting certificate powers in the NTC never repealed that exaction. The franchise and the certificate are distinct authorities that must concur, as the ruling in ACWS v. NTC (G.R. No. 144109, 2003) holds, so the operator cannot stay on the air on a permit alone.

2. Issuance Rules: Requirements, Public Interest Primacy, Prior Operator, Free Competition, Nature of CPC, Terms, Provisional Authority, When CPC Not Required

“To investigate, upon its own initiative, or upon complaint in writing, any matter concerning any public service as regards matters under its jurisdiction; to require any public service to furnish safe, adequate, and proper service as the public interest may require and warrant; to enforce compliance with any standard, rule, regulation, order or other requirement of this Act or of the Commission, and to prohibit or prevent any public service as herein defined from operating without having first secured a certificate of public convenience or public necessity and convenience, as the case may be.”

“No franchise, certificate, or any other form of authorization for the operation of a public utility shall be granted except to citizens of the Philippines or to corporations or associations organized under the laws of the Philippines, at least sixty per centum of whose capital is owned by such citizens; nor shall such franchise, certificate, or authorization be exclusive in character or for a longer period than fifty years.”

Protection rewards good standing, while competition serves the riding and calling public. A provisional grant answers urgency on a first look, while a final certificate answers merit after full hearing. A definite term bounds every grant, while exclusivity voids any grant that claims it.

Case: Phil Rabbit v. Gabatin, G.R. No. L-24472, July 31, 1968

Facts: Gabatin sought a certificate for twelve auto-trucks on the direct Caoayan to Grace Park line, incumbents opposed and claimed adequate service with full buses, and the Commission found no direct service since the incumbents ran mostly from Laoag and passed Vigan already full.

Issue: The issue was whether the Commission could grant a newcomer over the opposition of incumbents invoking the prior operator rule and attacking the evidence and the finances of the applicant.

Held: The Court held that it could, because findings on need and capability supported by substantial evidence are conclusive, a mere assertion of no evidence proves nothing, and the prior operator rule never applies automatically where public interest calls for the grant.

Doctrine: Commission findings of fact stand on substantial evidence, courts never weigh credibility de novo, and the prior operator rule yields to public service and public interest as the primordial considerations.

Case: Eastern Telecom v. Intl Communication, G.R. No. 135992, July 23, 2004

Facts: TTPI held a provisional authority over Manila and Navotas, the NTC granted ICC a second provisional authority over the same areas after finding ICC financially and technically capable with a feasible plan, and the incumbents claimed exclusivity under the old service area scheme.

Issue: The issue was whether the NTC gravely abused its discretion by authorizing a second carrier inside areas already assigned under a prior provisional authority.

Held: The Court held that it did not, because the later competition laws omitted the one-carrier scheme and adopted healthy competition, no grant is ever exclusive, and capability and demand findings supported by evidence deserve respect, with modification only to require the escrow deposit and performance bond for the new project.

Doctrine: The service area scheme is at most one factor and never ties the NTC, a prior provisional holder owns no exclusive territory, and each provisional project carries its own escrow and bond duties.

Case: Republic v. Republic Telephone, G.R. No. 64888, November 28, 1996

Facts: RETELCO operated the Malolos exchange under municipal and legislative franchises, the Bureau installed its own exchange there without first concluding a negotiated arrangement with the incumbent, and the trial courts permanently enjoined the Bureau at the suit of the franchisee.

Issue: The issue was whether the incumbent held an exclusive right and whether the missed prior negotiation voided the government operation.

Held: The Court held that it held none, because no franchise is ever exclusive, the negotiation proviso is phrased in permissive and directory terms, and the State may operate its own system for the general public, so the injunction had no legal basis and was dissolved.

Doctrine: Directory negotiation language never voids government entry, Bureau officials cannot bargain away services the law authorizes, and an ultra-protectionist reading that breeds monopoly and retards development is rejected.

Case: PLDT v. NTC, G.R. No. 88404, October 18, 1990

Facts: ETCI sought a certificate with provisional authority for a cellular system in Metro Manila, PLDT opposed on franchise coverage, prior operation, and harmful duplication, and the NTC granted an eighteen-month provisional authority limited to Phase A with an interconnection condition while continuing the main case.

Issue: The issue was whether the NTC gravely abused its discretion in granting provisional relief under a liberally read 1958 franchise and in compelling interconnection with the incumbent network.

Held: The Court held that it did not, because provisional relief needs only a prima facie showing of capability and public need, agency construction of technical franchises deserves respect, share sales need only Commission approval under Sec. 20(h) while franchise assignment needs Congress, forfeiture needs a direct quo warranto suit, and interconnection serves rapid expansion under police power and R.A. No. 6849.

Doctrine: A provisional authority is temporary, limited, non-exclusive, and revocable and never a final certificate, stock transfers are governed by Sec. 20(h) and never by the franchise anti-transfer clause, franchise forfeiture is never self-executing or collateral, and the State may compel interconnection since no utility owns a right to monopoly.

Case: Pangasinan Transportation v. PSC, G.R. No. 47065, June 26, 1940

Facts: The operator held long-standing route certificates, applied for ten additional trucks, and received new twenty-five-year limits with a Commonwealth acquisition condition on all its certificates without prior hearing.

Issue: The issue was whether the statute unduly delegated legislative power and whether the new conditions could reach existing certificates without hearing.

Held: The Court held that the delegation was valid because public interest is a sufficient standard capped at fifty years, that a certificate is a mere privilege reachable by police power, and that the new limit still needed prior notice and hearing so the case was remanded.

Doctrine: The Public Service Act is a valid police-power measure, public interest standards sustain subordinate legislation, a certificate confers no property right against the State, and new conditions on existing certificates require notice and hearing.

Q: An applicant proves Filipino citizenship and financial capacity for a direct route that no incumbent serves, since the incumbents run full buses from farther north and skip the town. The incumbents invoke the prior operator rule. Must the grant fail.

A: No, because public interest is the primordial consideration and the rule never applies automatically. The law protects incumbents only against needless or ruinous duplication, and the ruling in Phil Rabbit v. Gabatin (G.R. No. L-24472, 1968) sustains a grant where substantial evidence shows unserved need with a capable applicant. The Commission grants the newcomer and the opposition falls with the exclusivity claim.

Q: A carrier holds a provisional authority over two cities and claims exclusive rights there against a second applicant the regulator finds capable with a feasible plan. The first carrier cites the old one-carrier-per-area scheme. May the regulator authorize the second carrier.

A: Yes. Later competition laws replaced the one-carrier scheme with healthy competition, and no franchise, certificate, or authorization is ever exclusive in character. The ruling in Eastern Telecom v. Intl Communication (G.R. No. 135992, 2004) upholds the second provisional authority on capability and demand findings while imposing the separate escrow and bond for the new project. The incumbent keeps no monopoly and improves service instead.

Q: An incumbent telephone carrier refuses interconnection with a provisionally authorized cellular operator and claims a vested right to be spared competition. The regulator orders interconnection within ninety days. Is the order valid.

A: Yes, because interconnection expands public access and no utility holds a constitutional right to a monopoly. The law empowers the regulator to set interconnection terms, reinforced by the municipal telephone mandate, and the ruling in PLDT v. NTC (G.R. No. 88404, 1990) sustains the order where the newcomer showed prima facie capability with urgent public need. The incumbent interconnects while the main case continues.

3. Transfer of CPC and Other Transactions; Revocation or Cancellation

“To sell, alienate, mortgage, encumber or lease its property, franchises, certificates, privileges, or rights or any part thereof; or merge or consolidate its property, franchises privileges or rights, or any part thereof, with those of any other public service. The approval herein required shall be given, after notice to the public and hearing the persons interested at a public hearing, if it be shown that there are just and reasonable grounds for making the mortgaged or encumbrance, for liabilities of more than one year maturity, or the sale, alienation, lease, merger, or consolidation to be approved, and that the same are not detrimental to the public interest, and in case of a sale, the date on which the same is to be consummated shall be fixed in the order of approval: Provided, however, that nothing herein contained shall be construed to prevent the transaction from being negotiated or completed before its approval or to prevent the sale, alienation, or lease by any public service of any of its property in the ordinary course of its business.”

“To sell or register in its books the transfer or sale of shares of its capital stock, if the result of that sale in itself or in connection with another previous sale, shall be to vest in the transferee more than forty per centum of the subscribed capital of said public service. Any transfer made in violation of this provision shall be void and of no effect and shall not be registered in the books of the public service corporation. Nothing herein contained shall be construed to prevent the holding of shares lawfully acquired.”

“To sell, alienate or in any manner transfer shares of its capital stock to any alien if the result of that sale, alienation, or transfer in itself or in connection with another previous sale shall be the reduction to less than sixty per centum of the capital stock belonging to Philippine citizens. Such sale, alienation or transfer shall be void and of no effect and shall be sufficient cause for ordering the cancellation of the certificate.”

“To amend, modify or revoke at any time certificate issued under the provisions of this Act, whenever the facts and circumstances on the strength of which said certificate was issued have been misrepresented or materially changed.”

“To suspend or revoke any certificate issued under the provisions of this Act whenever the holder thereof has violated or willfully and contumaciously refused to comply with any order rule or regulation of the Commission or any provision of this Act: Provided, That the Commission, for good cause, may prior to the hearing suspend for a period not to exceed thirty days any certificate or the exercise of any right or authority issued or granted under this Act by order of the Commission, whenever such step shall in the judgment of the Commission be necessary to avoid serious and irreparable damage or inconvenience to the public or to private interests.”

Negotiation before approval is allowed, while consummation without approval is void. A share sale shifts investors and needs agency leave, while a franchise assignment shifts the grant and needs the grantors leave. A fine punishes and coexists with other remedies, while revocation ends the privilege for contumacious breach.

Case: Rizal Light v. Morong, G.R. Nos. L-20993 and L-21221, September 28, 1968

Facts: Rizal Light held a 1949 certificate for electric service in Morong, ignored voltage and metering directives from 1954, missed hearings and filings, and lost its certificate with forfeiture of its franchise, while Morong Electric took a municipal franchise before incorporation, incorporated a month later, and won its own certificate on findings of need and financial capacity.

Issue: The issue was whether long neglect of certificate conditions and directives justified revocation instead of a fine and whether the later municipal franchise and certificate survived the want of corporate existence at the grant.

Held: The Court held that both orders stood, because inspection reports substantially supported the findings, contumacious refusal since 1954 warranted revocation over a mere fine, protection of investment shields only operators of good standing, the later incorporation with acceptance perfected the municipal contract, and a municipal electric franchise becomes efficacious only upon Commission approval.

Doctrine: A certificate is a mere privilege forfeited for breach, fines are cumulative and never bar revocation, the protection rule never rewards neglect, a pre-incorporation municipal grant perfects upon organization and acceptance, and hearing defects are waived unless timely objected to before the Commission.

Case: Raymundo v. Luneta Motor, G.R. Nos. 39902 and 39903, November 29, 1933

Facts: Guzco Transit defaulted on truck notes secured by chattel mortgage, the creditor attached and garnished its three bus-line certificates through the Commission secretary and bought two of them at auction, and nine days after attachment the debtor privately sold all three certificates with some trucks to Raymundo.

Issue: The issue was whether certificates of public convenience are property liable to execution and which transfer prevails between the earlier auction sale and the later private sale.

Held: The Court held that the certificates are property liable to execution, because the holder may sell voluntarily with approval so the law allows involuntary taking by legal process, and the earlier attachment and auction prevailed over the later private sale made under levy.

Doctrine: Certificates carry material value and pass the beneficial-interest test for attachment, no statute exempts them from execution, the Commission may approve transfer to the execution creditor, and a private sale after levy never defeats the execution sale.

Q: A bus company sells sixty percent of its subscribed capital to a single buyer in two connected deeds without Commission approval and books the transfer. The buyer demands recognition as stockholder. Must the company register the buyer.

A: No, because every transfer vesting more than forty per centum of subscribed capital in one transferee without prior approval is void and unregistrable. The law counts connected previous sales together, as the ruling in PLDT v. NTC (G.R. No. 88404, 1990) applies Sec. 20(h), so the buyer holds nothing registrable and the company faces sanction if it books the sale.

Q: A certificate holder disobeys service directives for eight years, cures nothing after inspection reports and hearings, and pleads protection of its investments against revocation. Must the Commission settle for a fine.

A: No, because willful and contumacious refusal to obey orders and certificate conditions warrants cancellation and revocation. The fine remedy is cumulative and never bars revocation, and the ruling in Rizal Light v. Morong (G.R. Nos. L-20993 and L-21221, 1968) denies protection to an operator that is not of good standing. The Commission revokes the certificate and forfeits the franchise on substantial evidence.

Quick-Recall Tables

Exam Traps

1. A franchise answers the sovereign grant, while a certificate answers the regulatory permission and the two never collapse into one.
2. A required franchise plus a missing certificate still bars operation, and a certificate never cures a missing franchise.
3. Absence of a franchise goes to issuance on the merits, while only absence of statutory power goes to jurisdiction.
4. Delegation needs legislative standards of policy, citizenship, fitness, and procedure, and a roving commission fails.
5. A municipal franchise is inchoate until the grantee incorporates and accepts, and it becomes efficacious only upon Commission approval.
6. Citizenship and capability open the inquiry, yet only the public-interest finding closes it.
7. Full buses elsewhere prove nothing, and unserved direct demand with a capable applicant sustains the grant.
8. The prior operator rule protects against ruinous duplication, yet it never operates automatically against proven need.
9. A provisional permit answers urgency on first look, while only the final certificate answers merit after full hearing.
10. Provisional relief is temporary, limited, non-exclusive, and revocable, and it never ripens by mere lapse of time.
11. A one-carrier scheme yields to a later healthy-competition law, and the old rule never ties the regulator.
12. No provisional holder owns exclusive territory, and a second capable carrier may enter the same area.
13. Share sales need agency approval under Sec. 20(h), while franchise assignment needs the grantors approval.
14. Connected sales count together toward the forty percent ceiling, and structuring in tranches never evades it.
15. An alien transfer that drops Filipinos below sixty percent is void and independently cancels the certificate.
16. Forfeiture of a franchise is never self-executing and needs a direct quo warranto suit by the State.
17. A fine is cumulative and never bars revocation, and contumacious breach draws cancellation.
18. Certificates are privileges against the State yet property against creditors, so revocation and execution coexist.

Key Authorities Cited

Codes and Constitution: 1987 Constitution Art. XII Sec. 11 with Art. VI Sec. 23(2) on delegation; C.A. No. 146 Secs. 13(a), 14, 15, 16(a), 16(b), 16(m), 16(n), 17(a), 20(g), 20(h), 20(i), 32, 35 as amended by C.A. No. 454 and R.A. No. 11659, approved March 21, 2022.

Special laws and rules: R.A. No. 776 Secs. 4, 10, 12, 21; Act No. 3846 Sec. 1; P.D. No. 576-A Secs. 1, 6; E.O. No. 546 Sec. 15; P.D. No. 1; P.D. No. 857 Sec. 6; E.O. No. 94 Sec. 79(b); R.A. No. 7925 Secs. 4(f), 6, 10, 23; R.A. No. 6849; R.A. No. 2036 Secs. 1, 4(a), 15; R.A. No. 2090 Secs. 4, 10; NTC MC No. 11-9-93 Sec. 27; NTC MC No. 8-9-95; DOTC Circular No. 91-260; E.O. No. 109.

Cases: PAL v. CAB (G.R. No. 119528, 1997); RCPI v. NTC (G.R. No. L-68729, 1987); Albano v. Reyes (G.R. No. 83551, 1989); ACWS v. NTC (G.R. No. 144109, 2003); Phil Rabbit v. Gabatin (G.R. No. L-24472, 1968); Rizal Light v. Morong (G.R. Nos. L-20993 and L-21221, 1968); Eastern Telecom v. Intl Communication (G.R. No. 135992, 2004); Republic v. Republic Telephone (G.R. No. 64888, 1996); PLDT v. NTC (G.R. No. 88404, 1990); Raymundo v. Luneta Motor (G.R. Nos. 39902 and 39903, 1933); Pangasinan Transportation v. PSC (G.R. No. 47065, 1940).

Source and Verification Note

This reviewer reads Aquino 2024 Chapter 14 pages 949 to 978 against the Part III-B syllabus slice, with Batch 3 digests 57 and 61 to 70 and the compiled 2016 to 2025 commercial-law questionnaire. The scanned textbook carries no text layer so its discussion is rendered through the section headings of the TOC file and the full batch digests with LawPhil full-text addresses recorded in each digest source line. Authority language was checked against primary text: C.A. No. 146 Secs. 15, 16(a), 16(b), 16(m), 16(n), 17(a), 20(g), 20(h), and 20(i) against the LawPhil Commonwealth Act page, and Art. XII Sec. 11 against the LawPhil Constitution page. Case doctrine comes from the batch digests for PAL, RCPI, Albano, ACWS, Phil Rabbit, Rizal Light, Eastern Telecom, Republic Telephone, PLDT, Raymundo, and Pangasinan Transportation. The compiled questionnaire file carries no commercial-law question on franchise, certificate, provisional authority, or transfer doctrine for 2016 to 2025, so every drill in this reviewer is drafted from the doctrine and labeled accordingly with no year assigned. The amendatory law is R.A. No. 11659, approved March 21, 2022. The docket correction for ACWS follows the case list: G.R. No. 144109 decided February 17, 2003, since G.R. No. 144104 belongs to an unrelated case.