Title
Amalgamated Motors Philippines, Inc. vs. Secretary, Department of Transportation and Communications
Case
G.R. No. 206042
Decision Date
Jul 4, 2022
LTO bidding dispute: AMPI challenged bidding process irregularities; CA dissolved RTC's injunction, ruling prospective bidders lack clear legal right to halt process.
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Case Digest (G.R. No. 206042)

Facts:

Background of the Case
Amalgamated Motors Philippines, Inc. (AMPI) participated in a bidding process initiated by the Land Transportation Office (LTO) for the Supply and Delivery of Philippine Driver's License Cards. The LTO published an Invitation to Bid on May 24, 2010, and AMPI purchased the bidding documents and Terms of Reference (TOR) for P84,000.

Issues with the Bidding Process
The bidding process faced complications, prompting the LTO-Bids and Awards Committee (BAC) to defer the opening of bid documents. The Department of Transportation and Communications (DOTC) Secretary, Jose P. de Jesus, ordered a comprehensive review of the TOR, leading to its modification. The LTO-BAC later suspended the bidding process, and Secretary de Jesus issued Department Order (D.O.) No. 2010-36, creating a Special Bids and Awards Committee (SBAC).

New Invitation to Bid
On December 24, 2010, the DOTC-SBAC posted a new Invitation to Bid. Previous participants, including AMPI, were allowed to obtain new bid documents upon presenting their receipts. However, Realtime Data Management Services, Inc. (RDMSI), another prospective bidder, filed a Petition for Declaratory Relief with a Prayer for Injunction, alleging irregularities in the bidding process.

RTC's Issuance of Preliminary Injunction
The Regional Trial Court (RTC) granted RDMSI's application for a preliminary injunction, halting the bidding process. Secretary de Jesus then issued Special Order (S.O.) No. 2011-181, strengthening the BAC. Despite this, the DOTC posted a new Invitation to Bid in April 2012, leading AMPI to intervene and challenge the validity of D.O. No. 2010-36 and S.O. No. 2011-181.

CA's Reversal of RTC's Decision
The Court of Appeals (CA) reversed the RTC's orders, dissolving the writs of preliminary injunction. The CA ruled that AMPI and RDMSI, as prospective bidders, did not have a clear and unmistakable right to the injunctive writs.

Issue:

The sole issue in this case is whether the CA erred in dissolving the writs of preliminary injunction issued by the RTC.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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