Title
Alliance of Non-Life Insurance Workers of the Philippines vs. Mendoza
Case
G.R. No. 206159
Decision Date
Aug 26, 2020
DOTC's 2007 CTPL insurance integration order challenged; SC ruled moot due to 2018 DOTr revision, citing forum shopping and lack of standing.
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Case Digest (G.R. No. 206159)

Facts:

  1. Issuance of Department Order No. 2007-28:
    On July 5, 2007, the Department of Transportation and Communications (DOTC) issued Department Order No. 2007-28, which aimed to integrate the issuance and payment of Compulsory Third Party Liability (CTPL) Insurance with the Land Transportation Office (LTO). This was intended to eliminate fraudulent CTPL Insurance schemes.

  2. Provisions of DO No. 2007-28:
    The order required that CTPL Insurance be automatically issued upon motor vehicle registration or renewal using the LTO IT System, developed by Stradcom Corporation. The system would compute premiums, taxes, and other fees, and issue official receipts reflecting insurance coverage.

  3. Challenges to DO No. 2007-28:
    On July 7, 2008, the Alliance of Non-Life Insurance Workers of the Philippines (Alliance), Bukluran ng Manggagawa na Umaasa sa Industriya ng Seguro Inc. (BMIS), and Movement for the Upliftment of Non-Life Insurance, Inc. (MUNLI), filed a Petition for Certiorari before the Court of Appeals, challenging the validity of DO No. 2007-28.

  4. Supervening Regulation:
    On August 24, 2018, the Department of Transportation (DOTr) issued Department Order No. 020-18, which revised the guidelines for CTPL Insurance, recognizing the Insurance Commission's sole authority to determine qualified insurance providers. This new regulation effectively superseded DO No. 2007-28.

Issue:

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Ruling:

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Ratio:

  1. Correct Remedy:
    The petitioners correctly availed of certiorari and prohibition under Rule 65 to challenge DO No. 2007-28, as the DOTC's issuance was an exercise of quasi-legislative power, and judicial review of such acts is permitted under the Constitution.

  2. Legal Standing:
    The petitioners failed to establish legal standing as they did not sufficiently prove that their members were directly affected by DO No. 2007-28 or that they were authorized by their members to file the petition.

  3. Mootness:
    The issuance of DO No. 020-18, which superseded DO No. 2007-28, rendered the petition moot and academic. The new regulation revoked the integrated CTPL insurance system under DO No. 2007-28, making the petition unnecessary.

  4. Forum Shopping:
    The petitioners engaged in forum shopping by filing multiple petitions in different courts, seeking the same reliefs based on the same causes of action. This conduct warranted the dismissal of the petition and could lead to contempt proceedings against the petitioners and their counsel.

Consequences

The Court directed the petitioners and their counsels to show cause why they should not be held in contempt for willful and deliberate forum shopping.


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