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Board of Public Utility Commissioners v. Compaia General de Tabacos de Filipinas

Citation: 249 U.S. 425Docket: No. 253

Court: Supreme Court of the United States; April 14, 1919; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The case involves an appeal from a judgment by a lower court that annulled an order of the Board of Public Utility Commissioners of the Philippine Islands. The annulment was due to Section 16 (e) of Act 2307, which was found to violate the organic law by improperly delegating legislative power to the Board concerning the contents of annual reports required from a corporate common carrier. While the appeal was pending, the local legislature amended the statute through Act 2694, specifying the report contents, thus invalidating the provision in question. With the original order rendered inoperative due to the amendment, the court deemed the issue moot. Consequently, it reversed the lower court's judgment and remanded the case, instructing dismissal without costs to either party, adhering to established legal precedents.

Legal Issues Addressed

Delegation of Legislative Power

Application: The court found that Section 16 (e) of Act 2307 improperly delegated legislative authority to the Board of Public Utility Commissioners, violating the organic law.

Reasoning: The annulment was based on the finding that Section 16 (e) of Act 2307, under which the board operated, violated the organic law of the Philippines by delegating legislative power to the board regarding the contents of annual financial and operational reports from a corporate common carrier.

Judicial Review upon Legislative Amendment

Application: Upon legislative amendment of the statute, the court reversed the lower court's judgment and remanded the case with instructions to dismiss.

Reasoning: Following established precedents, the court reversed the judgment and remanded the case with instructions to dismiss it without costs to either party.

Mootness Doctrine

Application: The court decided that the issue was moot due to legislative amendments that rendered the original order inoperative.

Reasoning: As a result, the original order became inoperative, making the validity of the initial provision a moot issue.