Administrative Law

Case Digest
Act. 2

1. Gr. no, 183173, August 24 2016

The Chairman and Executive Director, Palawan Council for Sustainable

FACTS:
The Palawan Council for Sustainable Development (PCSD) issued Administrative Order
(A.O.) No. 00-05, regulating the transport of live fish from Palawan. Ejercito Lim,
operating as Bonanza Air Services, engaged in this business without obtaining PCSD
accreditation, leading to a dispute. The Air Transportation Office (ATO) initially
exempted ATO-authorized carriers, including Bonanza Air Services, from PCSD
accreditation. Still, PCSD issued a Notice of Violation and Show Cause Order against
Lim for non-compliance. Lim filed a petition for prohibition in the Court of Appeals (CA)
to challenge the PCSD's authority.

ISSUE::
Whether the Court of Appeals (CA) erred in declaring A.O. No. 00-05 and related orders
null and void for being issued beyond the PCSD's authority.

RULING:
The Supreme Court ruled in favor of the PCSD and reversed the CA's decision.

Statutory Authority of PCSD:

R.A. No. 7611 established the PCSD as the administrative body responsible for
implementing the Strategic Environmental Plan (SEP) for Palawan, aiming to protect
and enhance natural resources.
The PCSD had broad statutory powers, including formulating plans, policies, and
regulations necessary for SEP's implementation and coordinating with local
governments.
It was also authorized to impose penalties and sanctions related to SEP
implementation.
Validity of A.O. No. 00-05:

A.O. No. 00-05 was issued within the PCSD's statutory authority to fill in the details of
SEP implementation.
The PCSD could regulate the transport of live fish from Palawan to protect natural
resources.
The PCSD's authority extended to imposing accreditation requirements.
Resolution No. 03-211:
Resolution No. 03-211 amended A.O. No. 00-05, making accreditation mandatory for all
carriers except those belonging to the government.
The amendment was within the PCSD's authority to adapt regulations as circumstances
changed.

RATIONALE:
In conclusion, the Supreme Court upheld the validity of A.O. No. 00-05, finding that it
was well within the PCSD's statutory authority to regulate the transport of live fish from
Palawan and impose accreditation requirements. The Court also recognized the
PCSD's power to adapt regulations through Resolution No. 03-211. The CA's decision
declaring these orders null and void was reversed.

2. Gr . No. 198529, February 9, 2021

FACTS:
Manila Electric Company (Meralco) is a public utility corporation operating in the
National Capital Region. The City of Muntinlupa, initially a municipality, was converted
into a highly urbanized city by Republic Act No. 7926 (RA 7926) on March 1, 1995.
Municipal Ordinance No. 93-35 (MO 93-35) was enacted in Muntinlupa on January 1,
1994, imposing a franchise tax on businesses operating public utilities. Nelia A. Barlis,
the City Treasurer of Muntinlupa, demanded the payment of franchise tax from Meralco
for the period from 1992 to 1999. Meralco challenged the imposition, arguing that
municipalities did not have the authority to impose a franchise tax, which was the
prerogative of provinces and cities under RA 7160 (Local Government Code of 1991).

ISSUE:
Whether Muntinlupa City had the legal authority to impose a franchise tax on Meralco
during the period from 1992 to 1999.

RULING:
The Supreme Court ruled in favor of Meralco, declaring that Muntinlupa City lacked the
legal authority to impose a franchise tax on Meralco during the specified period.
Ultra Vires Nature of MO 93-35: The central issue in this case was whether MO 93-35,
particularly Section 25, was valid or ultra vires. The court found that Section 25 of MO
93-35 was invalid because it was enacted when Muntinlupa was still a municipality, and
municipalities did not have the authority to levy franchise taxes. The court emphasized
that Section 142 of RA 7160 expressly vested the power to impose franchise taxes in
provinces and cities, not municipalities. Therefore, MO 93-35 was ultra vires and null
and void from its inception.
Ineffectiveness of Conversion into a City: The conversion of Muntinlupa into a highly
urbanized city under RA 7926 did not retroactively cure the invalidity of MO 93-35. The
court held that Section 56 of the Charter of Muntinlupa City, which adopted Section 25
of MO 93-35, did not cure the defects of the ordinance. An ultra vires ordinance is a
nullity and cannot be enforced, even if there is a subsequent change in the political
status of the municipality. The court emphasized that the power to impose a franchise
tax is limited to provinces and cities under RA 7160, and this power cannot be conferred
retroactively to a municipality through conversion.

RATIONALE:
In summary, the Supreme Court ruled that Muntinlupa City lacked the legal authority to
impose a franchise tax on Meralco during the period in question, as MO 93-35 was ultra
vires and the conversion into a city did not cure its invalidity. This case underscores the
importance of adhering to legal authority and statutory provisions when imposing local
taxes and fees.

3. Gr. No. 194335, Nov. 17, 2020

FACTS:
Petitioners are public utility bus drivers in Metropolitan Manila.
The Metro Manila Development Authority (MMDA) issued Resolution No. 10-16 and
Memorandum Circular No. 08, Series of 2010, re-implementing the number coding
scheme for all public utility buses in Metro Manila from November 15, 2010, to January
15, 2011.
The scheme prohibited public utility buses from operating on specific days based on
their license plate ending numbers. Certain vehicles were exempted from this scheme.
Petitioners filed a Petition for Injunction, seeking to stop the MMDA from enforcing the
number coding scheme and to declare these issuances null and void.

ISSUE:
Whether the MMDA's issuance of the number coding scheme exceeded its authority
under Republic Act No. 7924, violated the powers of the Land Transportation
Franchising Regulatory Board (LTFRB) and Department of Transportation and
Communication (DOTC), and violated due process.

RULING:

MMDA's Authority:
The MMDA's issuance of the number coding scheme was within its authority under
Republic Act No. 7924, which grants the MMDA the power to regulate metro-wide
services in Metropolitan Manila, including traffic regulation.
The MMDA's rule-making power allows it to regulate traffic in the region, and the
number coding scheme falls within this purview.
LTFRB and DOTC Powers:
The MMDA's actions did not violate the powers of the LTFRB or DOTC. While these
agencies have regulatory authority over public transportation, the MMDA can regulate
traffic without diminishing the autonomy of local government units concerning purely
local matters.
The MMDA's role is to coordinate basic services without encroaching on local
government unit jurisdiction.
Due Process:
Procedural due process was not violated because notice and hearing were not required
when an administrative agency acts pursuant to its rule-making power.
The MMDA complied with the mandatory publication and filing requirements for
administrative issuances.
Petitioners' Standing:
The real parties in interest were the bus owners/operators or franchisees, not the
individual drivers. However, even if the petitioners were considered the real parties in
interest, their argument did not stand as a certificate of public convenience does not
confer a property right.
The regulation of public utility buses is in the interest of the general public and can
impose restrictions on their operation if reasonably necessary for the common good.

RATIONALE:
The Court dismissed the Petition for Injunction, upholding the MMDA's authority to
implement the number coding scheme. It found that the scheme was within the MMDA's
rule-making powers, did not violate the powers of the LTFRB or DOTC, and did not
violate due process. The regulation was considered reasonable for the benefit of the
greater public interest.
This case highlights the principle that the MMDA, as an administrative agency,
possesses the authority to implement traffic regulations in Metropolitan Manila and can
do so without violating the powers of other regulatory bodies, provided such regulations
are within the scope of its mandate and serve the common good. It also underscores
that procedural due process may not always require prior notice and hearing when
administrative agencies exercise their rule-making functions.

References:
G.R. No. 183173. (n.d.).
https://lawphil.net/judjuris/juri2016/aug2016/gr_183173_2016.html
G.R. No. 198529. (n.d.).
https://lawphil.net/judjuris/juri2021/feb2021/gr_198529_2021.html
G.R. No. 194335 - the lawphil project. (n.d.).
https://lawphil.net/judjuris/juri2020/nov2020/gr_194335_2020.html