Facts:

This case revolves around the Association of International Shipping Lines, Inc. (AISL) and the United Harbor Pilots' Association of the Philippines, Inc. (UHPAP). The conflict arose when the Philippine Ports Authority (PPA) issued Administrative Order (AO) No. 03-85 on March 1, 1985, mandating additional charges for pilotage service rendered during certain hours, specifically between 1800 and 0600 hours, as well as on Sundays and holidays, thus establishing nighttime and overtime pay for harbor pilots. Subsequently, on February 3, 1986, President Ferdinand Marcos enacted Executive Order (EO) No. 1088, which set a uniform fee structure for pilotage services, ostensibly repealing prior orders inconsistent with it. Following the issuance of several resolutions by the PPA, including Resolution Nos. 1486, 1541, and 1554, the PPA effectively disallowed the payment of nighttime and overtime premiums for harbor pilots.

As a result, AISL, along with its member companies, refused UHP

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Facts:

Background of Regulatory Issuances

• On March 1, 1985, the Philippine Ports Authority (PPA) issued Administrative Order (AO) No. 03-85, which substantially adopted provisions from Customs Administrative Order (CAO) No. 15-65 concerning the payment of additional charges for pilotage services rendered during nighttime (between 1800H to 1600H) and on Sundays or holidays.
• Section 16 of AO No. 03-85 expressly provided that vessels using harbor pilots were to pay premium fees for services performed during these periods (100% for foreign trade vessels and 50% for coastwise vessels), with specific conditions regarding the commencement and termination of service relative to sunrise.

Issuance of Executive Order and Subsequent PPA Resolutions

• On February 3, 1986, then-President Ferdinand E. Marcos issued Executive Order (EO) No. 1088, which established uniform and modified rates for pilotage services in all Philippine ports.
• EO No. 1088 fixed pilotage fees based on the vessel’s tonnage and included a general repealing clause stating that all conflicting orders or issuances were to be repealed or amended accordingly.
• Subsequent to EO No. 1088, the PPA issued several resolutions (notably Resolution Nos. 1486, 1541, and 1554) that effectively disallowed the collection of overtime or night shift differential and recalled earlier recommendations for a reasonable premium pay.

The Dispute and Procedural History

• Based on PPA Resolution No. 1486, petitioners—namely the Association of International Shipping Lines, Inc. (AISL) and its members—refused to pay the claimed additional premium for nighttime and overtime pilotage services.
• In response, the United Harbor Pilots’ Association of the Philippines, Inc. (UHPAP) threatened to discontinue pilotage services if their claims for additional compensation were ignored.
• Petitioners subsequently filed a petition for declaratory relief with the Regional Trial Court (RTC), Branch 36, Manila (Civil Case No. 96-78400), challenging:
• Whether EO No. 1088 authorized the payment of nighttime and overtime pay; and
• Whether the pilotage fee rate should be applied per pilotage maneuver or to the entire package of pilotage services.
• On January 26, 1998, the RTC granted the petition, declaring that UHPAP was not authorized to collect separate overtime or night shift differential, noting that the rates, as set in EO No. 1088, were intended to cover the entire package of pilotage services.
• UHPAP elevated the matter by filing a petition for review on certiorari (G.R. No. 133763) before the Supreme Court, raising additional issues regarding the implied repeal of provisions in AO No. 03-85 and the scope of the pilotage fee rates.
• The Supreme Court, in its decision, clarified that EO No. 1088 did not repeal the provisions of AO No. 03-85 because there was no explicit or manifest inconsistency between them and that the two issuances addressed distinct subject matters: basic compensation versus additional charges.

Subsequent Developments and Appellate Proceedings

• Following the Supreme Court decision which affirmed the validity of the additional compensatory scheme under AO No. 03-85 and rendered the PPA resolutions (1486, 1541, and 1554) without legal effect, UHPAP filed a motion for the issuance of a writ of execution before the RTC.
• The RTC denied the motion for execution on April 8, 2003, citing the Supreme Court decision, and subsequently issued an order clarifying the status of the PPA resolutions.
• UHPAP then petitioned the Court of Appeals (CA) for certiorari under Rule 65, contending that the RTC committed grave abuse of discretion in modifying the effect of the Supreme Court’s ruling.
• In its decision dated October 19, 2005, the CA partly granted UHPAP’s petition by setting aside portions of the RTC order that recited the invalidity of the PPA resolutions while affirming the denial of the writ of execution.
• Petitioners filed a motion for partial reconsideration before the CA, which was ultimately denied on March 23, 2006, leading to the present recourse before the Supreme Court.

Issue:

The Effect of EO No. 1088 on Additional Pilotage Compensation

• Whether EO No. 1088, with its general repealing clause, effectively repealed or superseded the provisions of CAO No. 15-65 and PPA AO No. 03-85 that provided for additional (nighttime and overtime) pay for pilotage services.

Interpretation of the Pilotage Fee Rate

• Whether the pilotage fee schedule set by EO No. 1088, which fixed rates based on the vessel’s tonnage, was intended to cover the entire package of pilotage services or to be applied separately to each pilotage maneuver (e.g., docking, undocking, anchorage, shifting, and special services).

PPA’s Authority and the Impact on Its Administrative Resolutions

• Whether EO No. 1088 deprived the PPA of its power to promulgate new rules and rates, including those enabling the collection of overtime and nighttime premium pay through subsequent resolutions.

Procedural and Legal Ramifications in the Context of Declaratory Relief

• The appropriateness of UHPAP’s procedural steps, including its motion for execution following declaratory relief, in light of the distinction between declaratory judgments and actions warranting execution.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)