Case Digest (G.R. No. L-4404) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 19, 2017, the Department of Transportation (DOTr) issued Department Order No. 2017-011, known as the Public Utility Vehicle Modernization Program (PUVMP), pursuant to Executive Orders Nos. 125, 125-A, and 202, with the declared purpose of promoting safe, efficient, and environment-friendly public utility vehicles (PUVs). Paragraph 5.2 of the Order required that older PUVs, including public utility jeepneys (PUJs), be phased out in favor of brand-new units compliant with Euro IV emission standards and that new franchised route certificates of public convenience (CPCs) be allocated prioritizing modern units. Bayyo Association, Inc., representing 430 PUJ operators and drivers in Metro Manila, together with its president, Anselmo D. Perweg, filed a petition for certiorari and prohibition under Rule 65 of the Rules of Court before the Supreme Court En Banc to nullify paragraph 5.2. They alleged that the provision constituted an invalid delegation of legislative power, violate Case Digest (G.R. No. L-4404) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Jurisdiction
- Petitioners: Bayyo Association, Inc. (an SEC‐registered group of 430 jeepney operators and drivers) and its President, Anselmo D. Perweg.
- Respondents: Secretary Arthur P. Tugade, Secretary Carlos S. Dominguez, Secretary Wendel Eliot Avisado, and Atty. Martin B. Delgra, representing the DOTr and LTFRB.
- Subject Matter – DO No. 2017-011 (PUV Modernization Program)
- Issued June 19, 2017 pursuant to EO No. 125 (as amended), EO No. 125-A, and EO No. 202, to require safer, efficient, environment-friendly PUVs.
- Paragraph 5.2 mandates “brand new and environmentally-friendly units” be prioritized in CPC allocation and deployment, with three sub-provisions:
- 5.2.1 – Defines “environmentally-friendly units” (electric drive or Euro IV+ engines).
- 5.2.2 – LTFRB to set age limits by major component year (chassis/engine), not registration/import year.
- 5.2.3 – Refurbished/rebuilt vehicles must pass type approval and emissions tests; refurbished/rebuilt PUBs may not substitute phased-out units.
- Petitioners’ Challenge
- Procedural remedy: Petition for Certiorari and Prohibition under Rule 65, seeking nullification of paragraph 5.2.
- Alleged defects: invalid delegation of legislative power; infringement of due process and equal protection; discriminatory phase-out of jeepneys; confiscatory subsidy scheme; violation of livelihood rights; breach of “Filipino First” policy.
Issues:
- Procedural Issues
- Do the petitioners possess the requisite legal standing (association, citizen, or taxpayer)?
- Did the petitioners violate the doctrine of hierarchy of courts by directly filing with the Supreme Court?
- Substantive Issue
- Is paragraph 5.2 of DO No. 2017-011 unconstitutional (invalid delegation; due process/equal protection violations; confiscatory; deprivation of livelihood; breach of Filipino First policy)?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)