ADMIN LAW March 14 Cases
Lagman vs. Ochoa Jr. /Lagman vs. Pichay
Case Digest
G.R. No. 197422 & 197950
Ponente
LEONEN, J
Decision Date
Nov 3, 2020
The Supreme Court upholds the constitutionality of Republic Act No. 10149, dismissing petitions
challenging its provisions, which aim to address the excesses and inefficiencies of government-
owned or controlled corporations (GOCCs) in the Philippines.
OutlineParagraph
Facts:
The case of Lagman v. Ochoa, Jr. involves the constitutionality of Republic Act No. 10149, also
known as the GOCC Governance Act. The law aims to address the excesses and inefficiencies of
government-owned or controlled corporations (GOCCs) in the Philippines. The consolidated
petitions filed by Representative Edcel C. Lagman and Prospero A. Pichay, Jr. challenge the
constitutionality of the law on various grounds, including violation of the right to security of tenure,
undue delegation of legislative powers, and breach of the equal protection clause.
The facts of the case are as follows: Congress conducted inquiries into the activities of some GOCCs
and uncovered several excesses and inefficiencies, such as the receipt of "obscene bonuses" by
board directors and the implementation of "excessively generous retirement schemes." Despite
these inefficiencies, GOCCs still declared dividends and received subsidies. In response to these
abuses, Republic Act No. 10149 was enacted on June 6, 2011, creating the Governance Commission
for GOCCs (Governance Commission) to optimize the State's ownership rights in GOCCs and
promote growth.
Issue:
The main issue raised in the case is whether Republic Act No. 10149 is unconstitutional. The
petitioners argue that the law violates the right to security of tenure, unduly delegates legislative
powers, arrogates a constitutional commission's jurisdiction, and breaches the equal protection
clause.
Ruling:
The Supreme Court ruled that the provisions of Republic Act No. 10149 are constitutional. The Court
held that Congress has the power to change the qualifications and terms of public offices, as long as
it is done in good faith and pursuant to clear policy objectives. The Court also found that the law
does not violate the right to security of tenure, as it only shortens the terms of incumbent CEOs and
appointive board members, and does not remove them from office without cause. The Court
further held that the delegation of powers to the Governance Commission is valid and does not
unduly infringe on legislative powers. The Court also found that the law does not violate the equal
protection clause, as the exemptions provided are based on substantial distinctions and are
germane to the purpose of the law. Finally, the Court held that the repeal of individual charters of
GOCCs by Republic Act No. 10149 is valid, as the law is considered more specific and directly related
to the organizational aspect of GOCCs.
Ratio:
The Supreme Court upheld the constitutionality of Republic Act No. 10149, dismissing the petitions
challenging its provisions. The Court ruled that the law does not violate the right to security of
tenure, does not unduly delegate legislative powers, does not breach the equal protection clause,
and validly repeals individual charters of GOCCs.
The Court explained that Congress has the power to change the qualifications and terms of existing
statutory offices, even if it removes or shortens the term of an incumbent. It cited Article IX-B,
Section 2(3) of the Constitution, which guarantees security of tenure for all officers or employees in
the civil service. The Court further explained that this security of tenure provision applies to both
career and non-career service positions, including those in GOCCs with original charters.
The Court also addressed the delegation of legislative power to the Governance Commission for
Government-Owned or Controlled Corporations (GCG). It explained that Congress can delegate
legislative power through contingent legislation or subordinate legislation. In this case, the Court
found that the delegation of power to the GCG is permissible because the law sets forth the policy
to be executed and provides a sufficient standard for the GCG to follow.
The Court further rejected the argument that the GCG has supplanted the constitutional mandate of
the Civil Service Commission. It explained that the GCG's powers and functions do not duplicate or
supplant the Civil Service Commission's mandate. The GCG's main thrust is to assess the
performance of GOCCs as public institutions, while the Civil Service Commission is tasked with
establishing a career service and promoting efficiency and integrity in the civil service.
In conclusion, the Court upheld the constitutionality of the provisions in Republic Act No. 10149 that
shorten the terms of incumbent CEOs and appointive directors of GOCCs. It found that these
provisions do not violate the right to security of tenure and that the delegation of legislative power
to the GCG is permissible.
ADMIN LAW March 14 Cases
Lagman vs. Ochoa Jr. /Lagman vs. Pichay
Case Summary:
The Supreme Court upholds the constitutionality of Republic Act No. 10149, dismissing petitions
challenging its provisions, which aim to address the excesses and inefficiencies of government-
owned or controlled corporations (GOCCs) in the Philippines.
Case Background and Petitioners
 The case involves the constitutionality of Republic Act No. 10149, also known as the GOCC
Governance Act, which addresses the excesses and inefficiencies of government-owned or
controlled corporations (GOCCs) in the Philippines.
 The petitioners in the case are Representative Edcel C. Lagman and Prospero A. Pichay, Jr.
 The petitioners argue that the law violates the affected officials' right to security of
tenure, unduly delegates legislative powers, arrogates a constitutional commission's
jurisdiction, and breaches the equal protection clause.
Purpose and Provisions of the GOCC Governance Act
 The law was enacted in response to the uncovered excesses and inefficiencies of some
GOCCs, such as the receipt of "obscene bonuses" by board directors and the
implementation of "excessively generous retirement schemes."
 The law aims to optimize the State's ownership rights in GOCCs and promote growth by
ensuring that operations are consistent with national development policies and programs.
 The law created the Governance Commission for GOCCs (Governance Commission), which
is empowered to evaluate the performance and determine the relevance of GOCCs, and
to reorganize, merge, streamline, abolish, or privatize them in consultation with the
relevant department or agency.
 The law also shortens the terms of incumbent CEOs and appointive board members to
one year.
Petitioners' Arguments and Supreme Court's Ruling
 The petitioners argue that the provisions of the law violate the security of tenure of
officials, unduly delegate legislative powers, infringe on the jurisdiction of the Civil Service
Commission, and violate the equal protection clause.
 The Supreme Court rules that the law does not violate the security of tenure as it only
shortens the terms of office and does not remove the officials from service.
 The Court finds that the delegation of powers to the Governance Commission is valid and
that the law does not duplicate or supplant the jurisdiction of the Civil Service
Commission.
 The Court also holds that the law does not violate the equal protection clause as there are
substantial distinctions between the GOCCs covered by the law and those exempted.
 The Supreme Court upholds the constitutionality of Republic Act No. 10149 and dismisses
the petitions challenging its provisions.
Constitutional Guarantees and Non-Delegation of Legislative Power
 The main issue in the case is whether the provisions of Republic Act No. 10149 violate the
constitutional guarantees of security of tenure and non-delegation of legislative power.
 The Supreme Court explains that the constitutional guarantee of security of tenure
extends to both career and non-career service positions in the civil service, including those
in GOCCs.
 The Court clarifies that the legislature has the power to change the qualifications and
shorten the terms of existing statutory offices, even if it affects the tenure of incumbents.
 The shortening of terms for appointive directors does not amount to removal from office,
but rather a separation from service when the term expires.
 Therefore, the provisions of Republic Act No. 10149 do not violate the constitutional
guarantee of security of tenure.
 The Court also explains that while the delegation of legislative power is generally
prohibited, there are two types of permissible delegation: contingent legislation and
subordinate legislation.
 Contingent legislation involves delegating the power to ascertain facts necessary to bring
a law into operation, while subordinate legislation involves delegating the power to "fill
in" the details of a statute.
 The Court finds that the delegation of powers to the Governance Commission falls under
subordinate legislation.
 The law provides a complete policy and a sufficient standard for the Governance
Commission to carry out its functions, and therefore, there is no undue delegation of
legislative power.
ADMIN LAW March 14 Cases
Distinction between Governance Commission and Civil Service Commission
 The Court clarifies that the powers and functions of the Governance Commission do not
duplicate or supplant the constitutional mandate of the Civil Service Commission.
 The Governance Commission's role is to assess the performance of GOCCs as public
institutions, while the Civil Service Commission's role is to administer and enforce the
merit system for all levels and ranks in the civil service.
 The two agencies have distinct and complementary functions, and therefore, there is no
violation of the Civil Service Commission's constitutional mandate.
Constitutionality of Republic Act No. 10149
 The Supreme Court upholds the constitutionality of the provisions of Republic Act No.
10149 challenged in the case.
 The shortening of terms for appointive directors and the creation of the Governance
Commission do not violate the constitutional guarantees of security of tenure and non-
delegation of legislative power.
Purpose and Exclusions of Republic Act No. 10149
 Republic Act No. 10149 aims to regulate and rationalize the compensation frameworks of
GOCCs in the Philippines.
 The petitioners argue that the law violates the equal protection clause, as it excludes
certain entities from its coverage.
 The law is a general law and cannot supersede specific GOCC charters, according to the
petitioners.
Supreme Court's Ruling on Constitutionality
 The Supreme Court upholds the constitutionality of Republic Act No. 10149.
 The Court states that the law is a valid exercise of legislative power and does not violate
the equal protection clause.
 The exclusions in the law are based on reasonable distinctions and are in line with the
specific mandates and functions of the excluded entities.
 The law does not repeal specific GOCC charters, as it contains a clear legislative intent to
modify or repeal inconsistent provisions.
 Congress has the discretion to make classifications for the purpose of enacting laws, as
long as the classifications are based on substantial distinctions and apply equally to all
members of the same class.
 Republic Act No. 10149 introduces valid changes to the terms and conditions of service in
GOCCs and addresses the reported abuses and inefficiencies in their operations.
Title
Abakada Guro Party List vs. Purisima
Case Digest
G.R. No. 166715
Ponente
CORONA, J
Decision Date
Aug 14, 2008
The case involves the constitutionality of Republic Act 9335, which establishes a rewards and
incentives system for officials of the Bureau of Internal Revenue and the Bureau of Customs, and
the Supreme Court ruled in favor of upholding the law, except for one section, on the grounds that
it does not violate equal protection or unduly delegate legislative power, but it does violate the
separation of powers by allowing legislative participation in the implementation and enforcement of
the law.
OutlineParagraph
(Trial Preview - Rewritten in paragraph form with full case understanding)
Facts:
The case involves the constitutionality of Republic Act 9335, also known as the Attrition Act of 2005,
which establishes a rewards and incentives system for officials of the Bureau of Internal Revenue
(BIR) and the Bureau of Customs (BOC). The petitioners, Abakada Guro Party List and its
officers/members, argue that the law violates equal protection by limiting the rewards and
incentives system to officials and employees of the BIR and BOC, and that it unduly delegates
legislative power to the President. They also challenge the creation of a congressional oversight
committee, claiming that it violates the separation of powers. The Supreme Court ruled in favor of
upholding the law, except for the provision on the congressional oversight committee.
The petitioners, Abakada Guro Party List and its officers/members, filed a petition challenging the
constitutionality of Republic Act 9335, which establishes a rewards and incentives system for
ADMIN LAW March 14 Cases
officials of the BIR and BOC. They argue that the law violates equal protection and unduly delegates
legislative power. The respondents are the Secretary of Finance, the Commissioner of the BIR, and
the Commissioner of the BOC. The decision was made by the Supreme Court on August 14, 2008.
Issue:
The main issue raised in the case is the constitutionality of Republic Act 9335. The petitioners argue
that the law violates equal protection by limiting the rewards and incentives system to officials and
employees of the BIR and BOC, and that it unduly delegates legislative power to the President. They
also challenge the creation of a congressional oversight committee, claiming that it violates the
separation of powers.
Ruling:
The Supreme Court ruled in favor of upholding the law, except for the provision on the
congressional oversight committee. The Court held that the law does not violate equal protection as
it is based on substantial distinctions between the BIR and BOC and other government agencies. The
Court also found that the law provides a sufficient standard for the delegation of power to fix
revenue targets. However, the Court declared the provision on the congressional oversight
committee unconstitutional as it violates the separation of powers.
Ratio:
The Court's ratio for upholding the law is that it does not violate equal protection as it is based on
substantial distinctions between the BIR and BOC and other government agencies. The Court also
found that the law provides a sufficient standard for the delegation of power to fix revenue targets.
However, the Court declared the provision on the congressional oversight committee
unconstitutional as it violates the separation of powers. The Court explained that the power to
implement and enforce the law belongs to the Executive branch, and the creation of a congressional
oversight committee allows legislative participation in the implementation and enforcement of the
law, which is a violation of the separation of powers.
Abakada Guro Party List vs. Purisima
Case Summary
G.R. No. 166715
Ponente
CORONA, J
Decision Date
Aug 14, 2008
The case involves the constitutionality of Republic Act 9335, which establishes a rewards and
incentives system for officials of the Bureau of Internal Revenue and the Bureau of Customs, and
the Supreme Court ruled in favor of upholding the law, except for one section, on the grounds that
it does not violate equal protection or unduly delegate legislative power, but it does violate the
separation of powers by allowing legislative participation in the implementation and enforcement of
the law.
Background of the Case
 The case revolves around the constitutionality of Republic Act 9335, which establishes a
system of rewards and incentives for officials of the Bureau of Internal Revenue (BIR) and
the Bureau of Customs (BOC).
 The petitioners, officers and members of the Abakada Guro Party List, challenge the law
on the grounds of equal protection, non-delegation of legislative power, and separation of
powers.
Creation of Rewards and Incentives Fund
 The law creates a Rewards and Incentives Fund, sourced from the excess collection of the
BIR and the BOC in relation to their revenue targets.
 The fund is allocated to the BIR and the BOC in proportion to their contribution in the
excess collection.
 Boards in the BIR and the BOC are established to prescribe the criteria and procedures for
the grant of rewards and incentives.
Violation of Equal Protection Clause
 The petitioners argue that the law violates the equal protection clause of the Constitution
because it only applies to officials and employees of the BIR and the BOC, and not to
officials and employees of other government agencies.
 They claim that there is no valid basis for this distinction.
Undue Delegation of Power
 The petitioners contend that the law unduly delegates the power to fix revenue targets to
the President, as it lacks a sufficient standard on that matter.
 They argue that the law should have provided clear guidelines or limitations for the
President to follow in setting revenue targets.
Violation of Separation of Powers
ADMIN LAW March 14 Cases
 The petitioners challenge the creation of a congressional oversight committee, arguing  The Court emphasizes the importance of public accountability and the presumption of
that it violates the doctrine of separation of powers. constitutionality in favor of the law.

 They claim that the legislative function is completed upon the enactment and approval of
the law, and the creation of the oversight committee allows legislative participation in the
implementation and enforcement of the law.

Respondents' Arguments

 The respondents argue that the petition is premature as there is no actual case or
controversy yet. Belgica vs. Ochoa

 They assert that the reward system will not breed mercenaries and that the law is in line Case Digest
with the accountability of public officers.
G.R. No. 208566, 208493, 209251 & L-20768
Supreme Court Decision
Ponente
 The Supreme Court upholds the constitutionality of Republic Act 9335, except for Section
PERLAS-BERNABE, J
12 which creates the congressional oversight committee.
Decision Date
 The Court finds that the petitioners have failed to show a personal stake in the outcome
of the case or an injury to themselves, making their petition procedurally infirm. Nov 19, 2013

 However, the Court recognizes the public interest in resolving the constitutional issues
raised by the petitioners.
 The Court emphasizes the principle of public accountability and the presumption of
constitutionality in favor of the law.
 The Court finds the distinction between the BIR and the BOC and other government
agencies reasonable and based on substantial differences in their functions and
responsibilities.
 The Court finds that the law provides sufficient standards for the President to follow in
setting revenue targets.
 The Court declares Section 12, which creates the congressional oversight committee, as
unconstitutional, as it allows legislative participation in the implementation and
enforcement of the law, violating the principle of separation of powers.
Conclusion
 The Supreme Court partially grants the petition, upholding the constitutionality of
Republic Act 9335 with the exception of Section 12.
The Supreme Court of the Philippines declares the Pork Barrel System unconstitutional, ruling that it
violates the principles of separation of powers, checks and balances, and accountability, and
perpetuates a culture of patronage politics and political dynasty. The Court also finds that the
system lacks transparency and accountability, allowing for potential abuse and corruption.
OutlineParagraph
(Trial Preview - Rewritten in paragraph form with full case understanding)
Facts:
The case of Belgica v. Ochoa involves a constitutional challenge to the Pork Barrel System in the
Philippines. The petitioners, including Greco Antonious Beda B. Belgica and Jose M. Villegas, Jr.,
argue that the system violates the principles of separation of powers, checks and balances, and
accountability, and perpetuates a culture of patronage politics and political dynasty. They also claim
that the system lacks transparency and accountability, allowing for potential abuse and corruption.
The Supreme Court of the Philippines, in a decision rendered on November 19, 2013, partially
granted the petitions. The Court found that there is an actual and justiciable controversy in the case,
as the issues raised involve a conflict of legal rights and are of paramount public interest. The Court
also held that the petitioners have standing to sue, as they are taxpayers and citizens who will be
affected by the unconstitutional use of public funds.
ADMIN LAW March 14 Cases
The Court rejected the argument that the issues raised are matters of policy not subject to judicial
review. It emphasized that the issues are legal questions within the Court's province to resolve, and
that it has a duty to settle actual controversies involving rights that are legally demandable and
enforceable.
The Court also addressed the doctrines of res judicata and stare decisis. It found that res judicata
does not apply, as the previous cases cited by the respondents involved different provisions of the
Pork Barrel System and did not resolve the broader constitutional issues raised in the present case.
The Court also determined that stare decisis does not fully apply, as the previous rulings in
Philconsa and LAMP were limited in scope and did not address the entirety of the Pork Barrel
System.
In its ruling, the Court declared that the 2013 PDAF Article and all other Congressional Pork Barrel
Laws similar to it are unconstitutional. The Court found that these laws violate the principles of
separation of powers, non-delegability of legislative power, checks and balances, accountability,
political dynasties, and local autonomy. The Court also held that the phrases "and for such other
purposes as may be hereafter directed by the President" in Section 8 of PD 910 and "to finance the
priority infrastructure development projects and to finance the restoration of damaged or
destroyed facilities due to calamities, as may be directed and authorized by the Office of the
President of the Philippines" in Section 12 of PD 1869, as amended by PD 1993, are unconstitutional
as they constitute undue delegations of legislative power.
Overall, the Court's decision in Belgica v. Ochoa declares the Pork Barrel System unconstitutional
and calls for reforms to ensure transparency, accountability, and the proper use of public funds.
Issue:
The issue in this case is whether the Pork Barrel System in the Philippines, specifically the 2013
PDAF Article and other Congressional Pork Barrel Laws similar to it, is constitutional.
Ruling:
The Supreme Court ruled that the Pork Barrel System, including the 2013 PDAF Article and all other
Congressional Pork Barrel Laws similar to it, is unconstitutional.
Ratio:
The Court based its decision on several grounds. First, it found that there is an actual and justiciable
controversy in the case, as the issues raised involve a conflict of legal rights and are of paramount
public interest. The Court also held that the petitioners have standing to sue, as they are taxpayers
and citizens who will be affected by the unconstitutional use of public funds.
The Court rejected the argument that the issues raised are matters of policy not subject to judicial
review. It emphasized that the issues are legal questions within the Court's province to resolve, and
that it has a duty to settle actual controversies involving rights that are legally demandable and
enforceable.
The Court also addressed the doctrines of res judicata and stare decisis. It found that res judicata
does not apply, as the previous cases cited by the respondents involved different provisions of the
Pork Barrel System and did not resolve the broader constitutional issues raised in the present case.
The Court also determined that stare decisis does not fully apply, as the previous rulings in
Philconsa and LAMP were limited in scope and did not address the entirety of the Pork Barrel
System.
In its ruling, the Court declared that the 2013 PDAF Article and all other Congressional Pork Barrel
Laws similar to it are unconstitutional. The Court found that these laws violate the principles of
separation of powers, non-delegability of legislative power, checks and balances, accountability,
political dynasties, and local autonomy. The Court also held that the phrases "and for such other
purposes as may be hereafter directed by the President" in Section 8 of PD 910 and "to finance the
priority infrastructure development projects and to finance the restoration of damaged or
destroyed facilities due to calamities, as may be directed and authorized by the Office of the
President of the Philippines" in Section 12 of PD 1869, as amended by PD 1993, are unconstitutional
as they constitute undue delegations of legislative power.
Overall, the Court's decision in Belgica v. Ochoa declares the Pork Barrel System unconstitutional
and calls for reforms to ensure transparency, accountability, and the proper use of public funds.
Belgica vs. Ochoa
Case Summary
G.R. No. 208566, 208493, 209251 & L-20768
Ponente
PERLAS-BERNABE, J
Decision Date
Nov 19, 2013
The Supreme Court of the Philippines declares the Pork Barrel System unconstitutional, ruling that it
violates the principles of separation of powers, checks and balances, and accountability, and
perpetuates a culture of patronage politics and political dynasty. The Court also finds that the
system lacks transparency and accountability, allowing for potential abuse and corruption.
Introduction
 The case of Belgica v. Ochoa involves a challenge to the constitutionality of the Pork Barrel
System in the Philippines.
ADMIN LAW March 14 Cases
 The Supreme Court declared the Pork Barrel System unconstitutional, citing concerns of
corruption and misuse of public funds.
 The Court emphasized the need for transparency and accountability in government
spending.
Parties Involved and Key Details
 The case was brought by several petitioners, including Greco Antonious Beda B. Belgica,
Jose M. Villegas, Jr., Jose L. Gonzalez, Reuben M. Abante, and Quintin Paredes San Diego.
 They filed separate petitions against various government officials, including the Executive
Secretary, Secretary of Budget and Management, and National Treasurer, as well as the
Senate and House of Representatives.
History and Evolution of the Pork Barrel System
 The Court provides a detailed history of the Pork Barrel System in the Philippines, tracing
its origins to American political practices and its evolution in the Philippines.
 The system refers to the allocation of government spending for localized projects, often at
the discretion of individual legislators.
 The system has been criticized for its lack of transparency and accountability, as well as
the potential for corruption and misuse of public funds.
Procedural Issues
 The Court addresses several procedural issues, including whether there is an actual case
or controversy, whether the issues raised are justiciable, and whether the petitioners have
legal standing to sue.
 The Court concludes that there is an actual and justiciable controversy, as the issues
raised involve a conflict of legal rights and are of paramount public interest.
 The petitioners, as taxpayers and citizens, have sufficient standing to challenge the
constitutionality of the Pork Barrel System.
 The Court rejects the argument that the issues raised are matters of policy not subject to
judicial review, explaining that the issues involve legal questions within the Court's
province to resolve.
Previous Rulings and Relitigation
 The Court determines that the previous rulings in Philconsa v. Enriquez and Abakada Guro
Party List v. Ermita do not bar the re-litigation of the constitutionality of the Pork Barrel
System.
 The previous rulings were limited in scope and did not address the broader constitutional
issues raised in the present cases.
Definition of Terms
 The Court defines the terms "Pork Barrel System," "Congressional Pork Barrel," and
"Presidential Pork Barrel."
 The Pork Barrel System refers to the collective body of lump-sum discretionary funds,
including the Congressional Pork Barrel and the Presidential Pork Barrel.
 The Congressional Pork Barrel refers to the allocation of funds to individual legislators,
while the Presidential Pork Barrel refers to the President's discretionary funds.
Substantive Issues
 The Court examines the separation of powers principle and concludes that the Pork Barrel
System violates this principle.
 The system allows legislators to unduly encroach on the executive branch's power to
implement the national budget.
 The Court emphasizes the need for a clear division of powers and the independence of
each branch of government.
Conclusion
 The Court declares the Pork Barrel System unconstitutional and emphasizes the need for
transparency and accountability in government spending.
 Reforms are called for to ensure that public funds are used for the benefit of the people
and not for personal gain or political patronage.
Introduction
 Case: Ales vs. Commission on Elections (L-28196, Nov. 9, 1967, 21 SCRA 774)
 Discusses the concept of "political questions" and the power of judicial review in the
Philippines
 Highlights the need for judicial review to prevent abuse of discretion by the Executive and
Legislative branches of government
ADMIN LAW March 14 Cases
Definition of "Political Questions" Conclusion

 "Political questions" involve issues of policy or discretion within the realm of the Executive  Concludes that the PDAF is an unconstitutional delegation of legislative power
or Legislative branches
 Members of Congress should not be treated as ATMs from which the public can withdraw
 Argues that judicial review should extend to cases of grave abuse of discretion by any funds for private purposes
branch or instrumentality of the government
 Calls for accountability and a government that prioritizes social justice
Precedents on Judicial Review of Political Acts

 Refers to previous jurisprudence, such as Ta ada v. Cuenco and Villarosa v. House of

Representatives Electoral Tribunal

 Demonstrates that even political acts, like ratification of treaties or decisions of electoral
tribunals, can be subject to judicial review if there is grave abuse of discretion

Concept of "Grave Abuse of Discretion"

 Defined as a capricious and whimsical exercise of judgment that evades a positive duty or Araullo vs. Aquino III
refuses to act in accordance with the law
Case Digest
 Provides examples of instances where the Senate and House of Representatives were
accused of grave abuse of discretion, but the court found they did not commit it G.R. No. 209287, 209135, 209136, 209155, 209164, 209260, 209442, 209517 & 209569

Scope of Judicial Review Ponente

BERSAMIN, J
 Argues that judicial review should not fully reverse the policy of caution and courtesy
towards political acts Decision Date
 Should be used to review political discretion that clearly violates fundamental values and Jul 1, 2014
principles in the Constitution
This Philippine Jurisprudence case examines the constitutionality of the Disbursement Acceleration
Doctrine of Stare Decisis Program (DAP) and its related issuances, focusing on the legal standing of the petitioners and the
violation of the separation of powers. The Court ultimately rules that the DAP violates the
 Principle that courts should adhere to precedent
Constitution and orders the respondents to account for and return the funds used under the
program.
 Argues that the use of precedents should not be mechanical and should be abandoned
when there is a continuing error in the interpretation of constitutional provisions OutlineParagraph
Unconstitutionality of the Priority Development Assistance Fund (PDAF) (Trial Preview - Rewritten in paragraph form with full case understanding)

 Also known as the "pork barrel" Facts:

 Allows members of Congress to allocate funds for projects in their respective districts This case, Araullo v. Aquino III, involves the constitutionality of the Disbursement Acceleration
Program (DAP) and its related issuances. The petitioners, including Maria Carolina P. Araullo, Judy
 Argues that the PDAF violates the principle of separation of powers and allows M. Taguiwalo, and several representatives and organizations, filed separate petitions challenging
interference in project implementation, which is the role of the Executive branch the constitutionality of the DAP and its implementation by the respondents, including President
ADMIN LAW March 14 Cases
Benigno Simeon C. Aquino III, Executive Secretary Paquito N. Ochoa Jr., and Secretary of the
Department of Budget and Management (DBM) Florencio B. Abad.
Issue:
The main issue raised in the case is whether the DAP violates Section 29(1) of Article VI of the 1987
Constitution, which states that "no money shall be paid out of the Treasury except in pursuance of
an appropriation made by law."
Ruling:
The Court ultimately ruled that the DAP is unconstitutional. It held that the DAP violates the
constitutional provision on the appropriation of public funds and the separation of powers. The
Court found that the DAP allowed the Executive to realign and use public funds without the proper
authority from Congress. It also found that the DAP violated the principle of public accountability by
allowing the release of funds upon the request of legislators. The Court ordered the respondents to
account for and return the funds used under the DAP.
Ratio:
The Court's decision was based on the argument that the DAP contravened the constitutional
provision on the appropriation of public funds. The Court held that the DAP allowed the Executive
to allocate public funds without the proper appropriation by law, thereby violating the Constitution.
The Court also emphasized the importance of the separation of powers and the need for the
Executive to respect the authority of Congress in appropriating public funds. The Court found that
the DAP violated this principle by allowing the Executive to realign and use public funds without the
proper authority from Congress. The Court also found that the DAP violated the principle of public
accountability by allowing the release of funds upon the request of legislators, which undermined
the proper allocation of public funds.
Araullo vs. Aquino III
Case Summary
G.R. No. 209287, 209135, 209136, 209155, 209164, 209260, 209442, 209517 & 209569
Ponente
BERSAMIN, J
Decision Date
Jul 1, 2014
This Philippine Jurisprudence case examines the constitutionality of the Disbursement Acceleration
Program (DAP) and its related issuances, focusing on the legal standing of the petitioners and the
violation of the separation of powers. The Court ultimately rules that the DAP violates the
Constitution and orders the respondents to account for and return the funds used under the
program.
Case Background and Parties Involved
 The case is Araullo v. Aquino III, which examines the constitutionality of the Disbursement
Acceleration Program (DAP) and its related issuances.
 The petitioners include Maria Carolina P. Araullo, Judy M. Taguiwalo, Luz Ilagan, Carlos
Isagani Zarate, and Renato M. Reyes.
 The respondents are Benigno Simeon C. Aquino III, Paquito N. Ochoa Jr., and Florencio B.
Abad.
Controversy Surrounding the DAP
 The controversy began when Senator Jinggoy Estrada revealed that some Senators had
been given additional funds as an "incentive" for voting in favor of the impeachment of
Chief Justice Renato C. Corona.
 Secretary Florencio Abad confirmed that these funds were part of the DAP, a program
designed to accelerate economic expansion.
 The funds were released based on the Senators' letters of request, and the DAP had been
instituted in 2011 to address slow disbursements and stimulate economic growth.
Arguments Against the DAP
 The petitioners argue that the DAP violates the Constitution, specifically Section 29(1) of
Article VI, which states that "No money shall be paid out of the Treasury except in
pursuance of an appropriation made by law."
 They also argue that the DAP violates the Equal Protection Clause, the system of checks
and balances, and the principle of public accountability.
Examination of the Philippine Budget Process
 The Court examines the four phases of the Philippine budget process: budget preparation,
budget legislation, budget execution, and accountability.
 It concludes that the DAP violates the Constitution because it allows the Executive to
realign funds without the necessary appropriation from Congress.
 The Court also finds that the DAP lacks transparency and accountability in the use of
public funds.
ADMIN LAW March 14 Cases
Court's Ruling and Orders  The Court applies the doctrine of operative fact to the adoption and implementation of
the DAP.
 The Court orders the respondents to account for and return the funds used under the
DAP.  This doctrine recognizes the existence of a law or executive act prior to its determination
of unconstitutionality and sustains its effects.
 It declares the DAP and its related issuances unconstitutional.
 The Court applies this doctrine to the DAP because the consequences resulting from its
 The Court emphasizes the importance of adhering to constitutional limitations on the implementation cannot be ignored or undone.
spending power of the Chief Executive and the need for transparency and accountability
in the use of public funds.  However, the doctrine of operative fact does not apply to the authors, proponents, and
implementors of the DAP unless there are findings of good faith in their favor by the
Summary of the Case
proper tribunals determining their liabilities.
 The case involves the constitutionality of the Disbursement Acceleration Program (DAP) Conclusion
implemented by the Philippine government.
 The Court declares certain acts and practices under the DAP and its implementing
 The petitioners argue that the DAP violated the Constitution because it did not have issuances as unconstitutional.
legislative authorization and because the funds used were not considered savings.
 It also declares the use of unprogrammed funds without meeting the conditions set by the
 The Office of the Solicitor General (OSG) argues that the DAP was a valid exercise of the General Appropriations Acts as void.
President's authority to faithfully execute the laws.
Gerochi vs. Department of Energy
 The Supreme Court agrees with the OSG's argument but also finds that some transfers
made under the DAP violated the Constitution. Case Digest

 The Court upholds the constitutionality of the DAP but declares certain transfers of funds G.R. No. 159796
made under the program as unconstitutional.
Ponente
 The decision provides guidelines for the proper implementation of the DAP and NACHURA, J
emphasizes the importance of adhering to the provisions of the Constitution and the
General Appropriations Acts in the allocation and use of public funds. Decision Date

Unconstitutional Aspects of the DAP Jul 17, 2007

 The petitioners argue that the DAP violates the separation of powers, the principle of The Supreme Court dismisses the case challenging the constitutionality of the Universal Charge
public accountability, and the equal protection clause. imposed under the Electric Power Industry Reform Act, ruling that it is not a tax but an exaction in
the exercise of the State's police power, and that there is no undue delegation of legislative power
 The Court declares that the DAP and its implementing issuances are unconstitutional. to the Energy Regulatory Commission.

 The DAP violated the separation of powers as it allowed the Executive to reallocate funds OutlineParagraph
without the approval of Congress.
(Trial Preview - Rewritten in paragraph form with full case understanding)
 The DAP also used unprogrammed funds without meeting the conditions set by the
Facts:
General Appropriations Acts.
The case involves a challenge to the constitutionality of the Universal Charge imposed under the
Doctrine of Operative Fact
Electric Power Industry Reform Act (EPIRA). The petitioners, Romeo P. Gerochi, Katulong Ng Bayan
ADMIN LAW March 14 Cases
(KB), and Environmentalist Consumers Network, Inc. (ECN), argue that the Universal Charge is a tax G.R. No. 159796
and that there is an undue delegation of legislative power to the Energy Regulatory Commission
(ERC). The facts of the case are as follows: Congress enacted the EPIRA on June 8, 2001, and it took Ponente
effect on June 26, 2001. The National Power Corporation-Strategic Power Utilities Group (NPC- NACHURA, J
SPUG) filed a petition with the Energy Regulatory Commission (ERC) for the availment of its share
from the Universal Charge for Missionary Electrification. The ERC issued an order provisionally Decision Date
approving the amount of the share and authorizing the collection of the same from end-users. The
ERC later modified its order to increase the amount of the share. The NPC-SPUG filed a motion for Jul 17, 2007
reconsideration, which the ERC granted. The NPC also filed a petition with the ERC for the approval The Supreme Court dismisses the case challenging the constitutionality of the Universal Charge
of its share from the Universal Charge for the Environmental charge. The ERC authorized the NPC to imposed under the Electric Power Industry Reform Act, ruling that it is not a tax but an exaction in
draw funds from the Special Trust Fund for watershed rehabilitation. The Panay Electric Company, the exercise of the State's police power, and that there is no undue delegation of legislative power
Inc. (PECO) charged the Universal Charge to the end-users as reflected in their electric bills. The to the Energy Regulatory Commission.
petitioners then filed a complaint challenging the constitutionality of the Universal Charge.
Parties Involved and Constitutional Challenge
Issue:
 Petitioners: Romeo P. Gerochi, Katulong Ng Bayan (KB), and Environmentalist Consumers
The main issues raised in the case are: 1) Whether or not the Universal Charge is a tax; and 2)
Network, Inc. (ECN)
Whether or not there is an undue delegation of legislative power to the ERC.

Ruling:
 Respondents: Department of Energy (DOE), Energy Regulatory Commission (ERC),
National Power Corporation (NPC)
The Supreme Court dismisses the case, ruling that the Universal Charge is not a tax but an exaction
in the exercise of the State's police power. The Court also finds that there is no undue delegation of  Constitutional challenge: Petitioners argue that the Universal Charge imposed under the
legislative power to the ERC. Electric Power Industry Reform Act is a tax and there is an undue delegation of legislative
power to the ERC.
Ratio:
Imposition of Universal Charge
The Court explains that the power to tax is an incident of sovereignty and is unlimited in its range,
while police power is the power of the state to promote public welfare by restraining and regulating  Section 34 of the Electric Power Industry Reform Act imposes a universal charge on all
the use of liberty and property. In this case, the Court concludes that the Universal Charge is electricity end-users.
imposed primarily for regulatory purposes and not for the generation of revenue. It is an exaction in
the exercise of the State's police power to promote the welfare of the public by ensuring the
 The charge is collected by distribution utilities and remitted to the Power Sector Assets
and Liabilities Management Group (PSALM Corp.) for distribution to the respective
availability of electricity to all areas of the country. The Court also finds that the EPIRA provides
beneficiaries.
sufficient standards to guide the ERC in the exercise of its powers, thus there is no undue delegation
of legislative power.
 The charge is imposed for various purposes, including payment for stranded debts and
In summary, the Supreme Court dismisses the case challenging the constitutionality of the Universal contract costs, missionary electrification, equalization of taxes and royalties,
Charge imposed under the EPIRA. The Court rules that the Universal Charge is not a tax but an environmental charge, and cross-subsidies.
exaction in the exercise of the State's police power. The Court also finds that there is no undue
Petitioners' Arguments
delegation of legislative power to the ERC.
 Petitioners argue that the Universal Charge has the characteristics of a tax and is collected
to fund the operations of the National Power Corporation (NPC).
Gerochi vs. Department of Energy
 They claim that the cases cited by the respondents, which involve regulatory charges, are
Case Summary not applicable to the Universal Charge.
ADMIN LAW March 14 Cases
 Petitioners contend that the charge is oppressive and confiscatory and amounts to
taxation without representation.

Respondents' Arguments

 Respondents argue that the Universal Charge is not a tax but an exaction in the exercise of
the State's police power.

 They contend that the charge is levied for a specific regulatory purpose, which is to ensure
the viability of the country's electric power industry.

 Respondents deny that there is an undue delegation of legislative power to the ERC.

Supreme Court's Ruling

 The Supreme Court dismisses the case and rules in favor of the respondents. Kilusang Mayo Uno vs. Aquino III

 The Court distinguishes between the power to tax and the police power, stating that the Case Digest
Universal Charge is an exaction imposed primarily in pursuit of the State's police G.R. No. 210500
objectives.
Ponente
 The Court finds that there is no undue delegation of legislative power to the ERC, as the
law provides sufficient standards and limitations for the exercise of its authority. LEONEN, J

 The Court notes that the Universal Charge is similar to other regulatory charges that have Decision Date
been upheld as valid exercises of police power.
Apr 2, 2019
 The Court concludes that the Universal Charge is constitutional and serves the public The court upholds the validity of the increase in contribution rate and maximum monthly salary
welfare. credit by the Social Security System, emphasizing the importance of actuarial calculations and
Summary deference to legislative and executive decisions.

 Gerochi v. Department of Energy is a case where the Supreme Court upholds the
constitutionality of the Universal Charge imposed under the Electric Power Industry
Reform Act.
 The Court rules that the charge is an exaction in the exercise of the State's police power
and there is no undue delegation of legislative power.
OutlineParagraph
(Trial Preview - Rewritten in paragraph form with full case understanding)
Facts:
This case involves a challenge to the validity of certain resolutions issued by the Social Security
Commission (SSC) regarding the increase in contributions for Social Security System (SSS) members.
The petitioners, including labor unions and individual workers, filed a Petition for Certiorari and
Prohibition to annul the issuances that implemented the increase. They argued that the increase
ADMIN LAW March 14 Cases
violated the Social Security Act and the Constitution, and that the delegation of power to the SSC
was vague and incomplete.
Issue:
The main issue raised in the case is whether the increase in contributions and the issuance of the
resolutions by the SSC are valid.
Ruling:
The Supreme Court ruled that the petitioners who are SSS members have legal standing to
challenge the increase in contributions as they will directly be affected by it. However, other
petitioners who failed to show how they will be directly affected did not have legal standing. The
Court also applied the doctrine of transcendental importance to relax the standing requirement for
certain petitioners, as the issue raised affects millions of Filipinos and is of paramount public
interest.
Ratio:
The Court then examined the validity of the exercise of the SSC's powers and the delegation of
power to the SSC. The petitioners argued that the resolutions were void for being issued under
vague and unclear standards in the Social Security Act. However, the Court held that collateral
attacks on a presumably valid law are not allowed and that the delegation of legislative power to
administrative agencies is allowed. The Court also found that the Social Security Act provided
sufficient standards for the SSC to fix the contribution rate and the monthly salary credits.
The Court further rejected the argument that the increase in contributions was unduly oppressive
upon the labor sector and an unlawful exercise of police power. The Court held that the increase
was reasonably necessary to promote social justice and maintain a sustainable social security
system. The Court also emphasized that it should not interfere with the policy decisions made by
the executive branch and that the determination of the proper ratio of contribution is within the
executive branch's authority.
Based on these reasons, the Court held that the resolutions issued by the SSC were valid and denied
the petitioners' request for a temporary restraining order and/or writ of preliminary injunction.
Kilusang Mayo Uno vs. Aquino III
Case Summary
G.R. No. 210500
Ponente
LEONEN, J
Decision Date
Apr 2, 2019
The court upholds the validity of the increase in contribution rate and maximum monthly salary
credit by the Social Security System, emphasizing the importance of actuarial calculations and
deference to legislative and executive decisions.
Case Background and Petitioners' Arguments
 The case involves a challenge to the validity of the Social Security System (SSS) premium
hike that took effect in January 2014.
 The petitioners, including labor organizations and individual workers, filed a Petition for
Certiorari and Prohibition seeking to annul the issuances that implemented the premium
hike.
 They argued that the increase in contributions violated the law and the Constitution, and
that the delegation of power to the Social Security Commission was unlawful.
Legal Standing and Relaxation of Standing Requirement
 The Supreme Court addressed the issue of legal standing, which refers to the personal and
substantial interest of a party in a case.
 The Court held that some of the petitioners, who were directly affected by the premium
hike, had legal standing.
 However, others did not demonstrate how they would suffer direct and material injury.
 The Court recognized the transcendental importance of the issues raised and relaxed the
standing requirement for those petitioners.
Requirements for Judicial Review
 The Court discussed the requirements for the exercise of judicial review, including the
existence of an actual case or controversy, ripeness for adjudication, exhaustion of
administrative remedies, and the need for the issue to be raised at the earliest
opportunity.
 The Court found that there was an actual case or controversy, as the petitioners alleged
violations of their rights under the law and the Constitution.
 However, the petitioners had failed to exhaust their administrative remedies, as they had
not filed a case before the Social Security Commission or sought reconsideration of the
assailed issuances.
ADMIN LAW March 14 Cases
 The Court emphasized the importance of the doctrine of exhaustion of administrative
remedies in respecting the legislative power to delegate authority to administrative
agencies.
Mootness and Exceptions to Mootness
 The Court addressed the issue of mootness, which occurs when a case is no longer
justiciable because the issue has been resolved or the relief sought is no longer available.
 The Court found that the issue of the premium hike's validity may be rendered moot, as
the Social Security Commission was set to issue new resolutions.
 However, the Court applied the exceptions to mootness, as the issues raised involved
violations of constitutional rights, were of paramount public interest, required the
formulation of controlling principles, and were capable of repetition yet evading review.
Validity of Assailed Issuances
 The Court discussed the validity of the assailed issuances.
 It held that the delegation of power to the Social Security Commission was valid, as the
law provided the necessary standards and limitations for the exercise of the delegated
power.
 The Court rejected the argument that the issuances were void for being based on vague
and unclear standards, as the law specified the factors to be considered in fixing the
contribution rate and the minimum and maximum amounts of monthly salary credits.
Conclusion
 The Supreme Court denied the petition for lack of merit.
 The petitioners had failed to exhaust their administrative remedies and the assailed
issuances were found to be valid.
PNOC Alternative Fuels Corp. vs. National Grid Corporation of the Philippines
Case Digest
G.R. No. 224936
Ponente
CAGUIOA, J
Decision Date
Sep 4, 2019
The Supreme Court affirms the expropriation of land by the National Grid Corporation of the
Philippines for a transmission line project, ruling it as valid and necessary, while also upholding the
procedural correctness of the appeal filed by PNOC Alternative Fuels Corporation directly before the
Supreme Court.
OutlineParagraph
(Trial Preview - Rewritten in paragraph form with full case understanding)
Facts:
The case of PNOC Alternative Fuels Corp. v. National Grid Corporation of the Philippines involves an
appeal filed by PNOC Alternative Fuels Corporation (PAFC) against the expropriation of its land by
the National Grid Corporation of the Philippines (NGCP) for a transmission line project. In 2011,
NGCP filed a Complaint for Expropriation against PAFC and other parties, seeking to expropriate a
certain area of land for the construction and maintenance of a transmission line project. PAFC
argued that the land is already devoted to a public purpose and therefore cannot be expropriated.
The Regional Trial Court (RTC) issued an Order of Expropriation, ruling in favor of NGCP and
directing the parties to submit the names of commissioners for the determination of just
compensation. PAFC filed a Motion for Reconsideration, which was denied by the RTC. PAFC then
filed an appeal before the Supreme Court.
Issue:
The main issues raised in the case are: (1) whether PAFC was correct in filing its appeal directly
before the Supreme Court, and (2) whether the RTC was correct in issuing the Order of
Expropriation, which held that NGCP has the authority to expropriate the land under the law.
Ruling:
The Supreme Court ruled that PAFC did not commit a procedural error in filing the appeal directly
before the Court. The Court held that the appeal, although mistakenly worded as a "Petition for
Certiorari," is for all intents and purposes a petition for review on certiorari under Rule 45. The
Court also held that the appeal raises pure questions of law, which warrant the direct filing of the
appeal before the Court.
Regarding the validity of the Order of Expropriation, the Court held that the subject property is
considered patrimonial property that assumes the nature of private property. The Court explained
that the subject property, although owned by a State instrumentality, is managed and operated by
the State in its private capacity for economic ends. The Court also held that the expropriation by
NGCP is reasonably necessary for the construction and maintenance of the transmission line
project, as supported by the allegations in the Complaint and the Tripartite Agreement entered into
by the parties.
Ratio:
ADMIN LAW March 14 Cases
The Supreme Court affirmed the validity of the expropriation of the land by NGCP and upheld the Arguments Raised by PAFC
procedural correctness of PAFC's appeal filed directly before the Court. The Court ruled that NGCP
has the lawful right to expropriate the land for the transmission line project, and that the  PAFC argued that the expropriation was invalid because the land was already devoted to a
expropriation is reasonably necessary for the realization of the purposes for which NGCP's franchise public purpose, specifically the petrochemical industry, which it considered essential to
is granted. The Court based its decision on the fact that the subject property is considered the national interest.
patrimonial property and is managed and operated by the State in its private capacity for economic
 PAFC also argued that only Congress had the power to exercise eminent domain over the
ends. The Court also considered the allegations in the Complaint and the Tripartite Agreement as
subject property.
evidence of the reasonable necessity of the expropriation for the construction and maintenance of
the transmission line project. Ruling of the Regional Trial Court (RTC)

 The RTC issued an Order of Expropriation, ruling that NGCP had the lawful right to
PNOC Alternative Fuels Corp. vs. National Grid Corporation of the Philippines expropriate the subject property for public use upon payment of just compensation.

Case Summary  The RTC held that there was no law or jurisprudence stating that a property already
devoted to public use is invulnerable to expropriation.
G.R. No. 224936
 PAFC filed a Motion for Reconsideration, which was denied by the RTC.
Ponente

CAGUIOA, J
Appeal to the Supreme Court
Decision Date
 PAFC appealed the RTC's Order of Expropriation directly to the Supreme Court, arguing
Sep 4, 2019 that the expropriation was improper and without legal basis.
The Supreme Court affirms the expropriation of land by the National Grid Corporation of the
 NGCP argued that the appeal should have been filed with the Court of Appeals and that
Philippines for a transmission line project, ruling it as valid and necessary, while also upholding the
the issues raised in the appeal were not purely legal questions.
procedural correctness of the appeal filed by PNOC Alternative Fuels Corporation directly before the
Supreme Court.  The Supreme Court ruled that PAFC's appeal was properly filed under Rule 45 of the Rules
of Court, which allows direct appeals to the Supreme Court for cases involving purely legal
Background of the Case
questions.
 The case involves an appeal filed by PNOC Alternative Fuels Corporation (PAFC) against
Validity of the Expropriation
the expropriation of its land by the National Grid Corporation of the Philippines (NGCP) for
a transmission line project.  The Supreme Court held that the subject property, although owned by a state
instrumentality, was considered patrimonial property that assumes the nature of private
 NGCP, a private corporation engaged in transmitting electric power, sought to expropriate
property.
a certain area of land in Mariveles, Bataan and Limay, Bataan for the construction and
maintenance of a transmission line project.  The Court relied on the fact that the land was declared alienable and disposable by law
and could be transferred or conveyed to private persons for commercial utilization.
 The land in question is part of the Petrochemical Industrial Park, which was originally
reserved by the government for the Lamao Horticultural Experiment Station.  Therefore, NGCP had the authority to expropriate the subject property.

 Over the years, the ownership and administration of the land were transferred to Reasonableness and Necessity of the Expropriation
different government agencies, including PNOC.
ADMIN LAW March 14 Cases
 The Court found that the expropriation was reasonable and necessary for the realization
of the purposes for which NGCP's franchise was granted.
 PAFC did not specifically deny the allegations made by NGCP regarding the necessity of
the transmission line project for ensuring the stability and reliability of power supply in
the provinces of Bataan and Zambales.
 The Court also considered the Tripartite Agreement entered into by the parties, which
acknowledged the necessity of the project and the agreement on a revised route.
The case of Pantaleon v. Metro Manila Development Authority involves a petition filed by public
utility bus drivers seeking to enjoin the Metro Manila Development Authority (MMDA) from
enforcing the number coding scheme. The number coding scheme prohibits certain vehicles from
operating on specific days of the week in order to address traffic congestion in Metro Manila. The
petitioners argue that the MMDA exceeded its authority in issuing the challenged issuances and
that they encroach upon the powers of the Land Transportation Franchising and Regulatory Board.
They also claim that the issuances violate their right to due process.
Issue:

Supreme Court's Decision The main issues raised in the case are:

 Based on the findings, the Supreme Court affirmed the RTC's Order of Expropriation, 1. Whether the Supreme Court has jurisdiction to take cognizance of the petition;
upholding the validity of the expropriation of the subject property by NGCP.
2. Whether the MMDA has the legal authority to issue and implement the challenged
issuances;

3. Whether the challenged issuances encroach upon the powers of the Land Transportation
Franchising and Regulatory Board;

4. Whether the petitioners are the real parties-in-interest who can properly invoke the
relevant provisions of Executive Order No. 202; and
Pantaleon vs. Metro Manila Development Authority 5. Whether the challenged issuances violate the due process clause of the Constitution.
Case Digest Ruling:
G.R. No. 194335 The Supreme Court held that:
Ponente 1. It has jurisdiction to take cognizance of the petition due to the transcendental importance
and urgency of the issues involved. While the Regional Trial Court has original jurisdiction
LEONEN, J
over injunction cases, the Court can deviate from the rule on hierarchy of courts when
Decision Date there are compelling reasons or when the nature and importance of the issues warrant its
immediate exercise of jurisdiction.
Nov 17, 2020
2. The MMDA has the legal authority to issue and implement the challenged issuances.
Public utility bus drivers petition to stop the Metro Manila Development Authority (MMDA) from Under Republic Act No. 7924, the MMDA is vested with the authority to regulate traffic in
enforcing the number coding scheme, but the Supreme Court rules in favor of the MMDA, Metropolitan Manila. The Court held that the number coding scheme is a valid exercise of
upholding its authority to regulate traffic and concluding that the scheme is a reasonable regulation the MMDA's power to regulate traffic and is a reasonable regulation in the interest of the
in the interest of the general public. general public.
OutlineParagraph 3. The challenged issuances do not encroach upon the powers of the Land Transportation
Franchising and Regulatory Board. The MMDA's authority to regulate traffic in
(Trial Preview - Rewritten in paragraph form with full case understanding)
Metropolitan Manila is separate and distinct from the LTFRB's authority to grant, amend,
Facts: modify, or revoke franchises issued to public utility operators.
ADMIN LAW March 14 Cases
4. The petitioners are not the real parties-in-interest who can properly invoke the relevant Pantaleon vs. Metro Manila Development Authority
provisions of Executive Order No. 202. The real parties-in-interest are the bus
owners/operators or franchisees who can invoke any right invaded under their franchise. Case Summary

5. The challenged issuances do not violate the due process clause of the Constitution. G.R. No. 194335
Procedural due process does not require prior notice and hearing when an administrative Ponente
agency acts pursuant to its rule-making power. The Court also held that the operation of
public utility buses is imbued with public interest and may be subjected to reasonable LEONEN, J
restrictions for the benefit of the greater number. The Court found no arbitrariness,
oppressiveness, or unreasonableness in the implementation of the issuances. Decision Date

Ratio: Nov 17, 2020

The Court's decision was based on the following arguments and legal basis:
1. The Supreme Court has jurisdiction to take cognizance of the petition due to the
transcendental importance and urgency of the issues involved. The Court can deviate
from the rule on hierarchy of courts when there are compelling reasons or when the
nature and importance of the issues warrant its immediate exercise of jurisdiction.
Public utility bus drivers petition to stop the Metro Manila Development Authority (MMDA) from
enforcing the number coding scheme, but the Supreme Court rules in favor of the MMDA,
upholding its authority to regulate traffic and concluding that the scheme is a reasonable regulation
in the interest of the general public.
Background of the Case

2. The MMDA has the legal authority to issue and implement the challenged issuances under
Republic Act No. 7924, which vests the MMDA with the authority to regulate traffic in
Metropolitan Manila. The number coding scheme is a valid exercise of the MMDA's power
to regulate traffic and is a reasonable regulation in the interest of the general public.
3. The challenged issuances do not encroach upon the powers of the Land Transportation
Franchising and Regulatory Board. The MMDA's authority to regulate traffic in
Metropolitan Manila is separate and distinct from the LTFRB's authority to grant, amend,
modify, or revoke franchises issued to public utility operators.
4. The petitioners are not the real parties-in-interest who can properly invoke the relevant
provisions of Executive Order No. 202. The real parties-in-interest are the bus
owners/operators or franchisees who can invoke any right invaded under their franchise.
5. The challenged issuances do not violate the due process clause of the Constitution.
Procedural due process does not require prior notice and hearing when an administrative
agency acts pursuant to its rule-making power. The operation of public utility buses is
imbued with public interest and may be subjected to reasonable restrictions for the
benefit of the greater number. The Court found no arbitrariness, oppressiveness, or
unreasonableness in the implementation of the issuances.
In conclusion, the Supreme Court dismissed the petition for injunction, upholding the authority of
the MMDA to enforce the number coding scheme and finding that the challenged issuances are
valid and reasonable regulations in the interest of the general public.
 The case of Pantaleon v. Metro Manila Development Authority involves a petition filed by
public utility bus drivers.
 The drivers sought to enjoin the Metro Manila Development Authority (MMDA) from
enforcing the number coding scheme for public utility buses.
 The drivers claimed that their right to work and earn a decent living was affected without
due process of law.
Arguments of the Petitioners
 The petitioners are bus drivers plying the routes between SM Fairview and Baclaran.
 They argued that the MMDA's issuances, specifically Metro Manila Development
Authority Resolution No. 10-16 and Memorandum Circular No. 08, Series of 2010,
contravened the law.
 They claimed that the MMDA and the Metro Manila Council have no legislative and police
power.
 They argued that the administrative issuances constituted an exercise of rule-making
authority beyond their powers.
 They also argued that the issuances encroached upon the powers of the Land
Transportation Franchising and Regulatory Board, which has exclusive jurisdiction over
public utility operators.
ADMIN LAW March 14 Cases
Supreme Court's Ruling on MMDA's Authority

 The Supreme Court held that the MMDA had the legal authority to issue and implement
the challenged issuances.

 It ruled that the MMDA's power to regulate traffic under its charter, Republic Act No.
7924, allowed it to impose the number coding scheme on public utility buses.

 The Court rejected the argument that the issuances encroached upon the powers of the
Land Transportation Franchising and Regulatory Board.

 There was no provision in the law conferring exclusive power or authority to regulate the
operation of public utility buses to the Board.

Supreme Court's Ruling on Due Process

 The Court held that the challenged issuances did not violate the due process clause of the
Constitution.

 It explained that notice and hearing are not essential when an administrative agency acts
pursuant to its rule-making power.

 The Court emphasized that a certificate of public convenience, which the bus drivers held,
is a mere privilege and does not confer a property right.

 The operation of public utility buses is subject to regulation in the interest of the general
public.

Conclusion of the Case

 The Supreme Court upheld the authority of the MMDA to enforce the number coding
scheme for public utility buses.

 The Court dismissed the petition filed by the bus drivers.

 The Court ruled that the MMDA's issuances were valid and within its powers under its
charter.

 The issuances did not violate the due process clause of the Constitution.