Title
Anglo-Fil Trading Corp. vs Lazaro
Case
G.R. No. L-54958
Decision Date
Sep 2, 1983
Stevedoring operators challenged PPA's exclusive contract with OTSI, alleging abuse of discretion and constitutional violations. The Supreme Court upheld PPA's authority, citing public interest and efficiency, while ensuring worker protection.
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Case Digest (G.R. No. L-54958)

Facts:

  1. Background of the Case: The case involves two petitions for certiorari filed by stevedoring operators and contractors against the Philippine Ports Authority (PPA) and Ocean Terminal Services, Inc. (OTSI). The petitioners sought to annul the order of the Court of First Instance of Manila, which lifted restraining orders preventing the implementation of an exclusive stevedoring contract awarded to OTSI for the South Harbor, Port of Manila.

  2. Stevedoring Operations: Stevedoring involves the handling of cargo from ships to docks or barges, including loading and unloading. The PPA, created under Presidential Decree No. 857, is tasked with managing and controlling ports, including stevedoring operations.

  3. Integration Policy: Prior to the controversy, 23 contractors operated at the South Harbor. The PPA adopted a policy of integrating stevedoring services, aiming to appoint a single contractor per port to improve efficiency and prevent pilferage.

  4. Exclusive Contract Award: Following an evaluation by a special committee, OTSI was recommended and awarded an exclusive five-year stevedoring contract for the South Harbor. President Ferdinand Marcos approved this award.

  5. Legal Challenges: Petitioners, including Philippine Integrated Port Services, Inc. (PIPSI) and Anglo-Fil Trading Corporation, challenged the contract in court, arguing that it violated their rights and was contrary to public interest. Temporary restraining orders were issued but later lifted by the court.

  6. Intervention by Labor Groups: The Katipunan ng mga Manggagawa sa Daungan (KAMADA) intervened, claiming their members would lose jobs if the contract was implemented.

Issue:

  1. Whether the respondent judge acted with grave abuse of discretion by lifting the temporary restraining orders ex-parte.
  2. Whether the PPA has the authority to award an exclusive stevedoring contract to OTSI.
  3. Whether the exclusive contract violates constitutional provisions on monopolies, due process, and equal protection.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)


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