Case Digest (G.R. No. 188760)
Facts:
On March 21, 2003, the Social Justice Society (SJS), through Atty. Vladimir Alarique T. Cabigao, filed a Petition for Declaratory Relief (Civil Case No. 03-106101) before the Regional Trial Court (RTC), Manila, Branch 26, against Pilipinas Shell Petroleum Corporation, Caltex Philippines, Inc., and Petron Corporation (collectively, the “Big 3”). SJS alleged that the Big 3’s uniform practice of raising petroleum prices after increases in the world crude oil market constituted monopoly and combination in restraint of trade under Article 186 of the Revised Penal Code and cartelization under Section 11(a) of Republic Act (RA) No. 8479 (Downstream Oil Industry Deregulation Act). The oil companies moved to dismiss, citing lack of standing, cause of action, jurisdiction, and failure to exhaust administrative remedies. On December 17, 2003, the RTC denied these motions and referred the controversy to the DOE-DOJ Joint Task Force created under RA 8479, suspending proceedings pending its iCase Digest (G.R. No. 188760)
Facts:
- Factual Antecedents
- On March 21, 2003, Social Justice Society (SJS) filed a Petition for Declaratory Relief (Civil Case No. 03-106101) before the RTC Manila, Branch 26, against Pilipinas Shell Petroleum Corp., Caltex Philippines, Inc., and Petron Corp. (the “Big 3”), alleging that they increase petroleum prices in concert, thereby violating Article 186 of the RPC and Section 11(a) of RA 8479. The petition was later amended to add Atty. Cabigao.
- The Big 3 moved to dismiss for lack of standing, cause of action, jurisdiction, and for failure to exhaust administrative remedies.
- RTC Proceedings and Referral
- On December 17, 2003, the RTC denied the Big 3’s motions to dismiss, suspended proceedings, and referred the case to the DOE-DOJ Joint Task Force under Section 11 of RA 8479. Reconsideration was denied on June 30, 2004.
- On April 17, 2008, the Task Force reported no violation by the Big 3. The Big 3 orally moved for dismissal; private respondents moved to open and examine the Big 3’s books.
- Assailed RTC Orders
- April 27, 2009 Order: Denied dismissal motions; granted motion to open books; ordered COA, BIR, and BOC to examine Big 3 accounts for January–December 2003.
- May 5, 2009 Order: Directed COA, BIR, and BOC to form an examiner panel and submit a report within three months.
- June 23, 2009 Order: Granted intervention to Pasang Masda, Inc., admitting its petition-in-intervention.
- July 7, 2009 Order: Denied motions for reconsideration; included Cabigao in the examiner panel; threatened contempt proceedings against non-complying agencies.
Issues:
- G.R. No. 188760 (OSG-COA, BIR, BOC)
- Did the RTC gravely abuse discretion by ordering COA, BIR, and BOC to perform ultra vires acts?
- Did the RTC usurp the DOE-DOJ Task Force’s authority, improperly invoking parens patriae and Rule 27?
- Did the RTC violate due process by threatening contempt against non-parties without notice?
- G.R. No. 189060 (Chevron)
- Does the petition present a justiciable, ripe controversy within the judicial power for declaratory relief?
- Does the RTC have jurisdiction to conduct an antitrust preliminary investigation under RA 8479?
- G.R. No. 189333 (Petron)
- Did the RTC abuse discretion in denying Petron’s motion to dismiss when the petition sought an advisory opinion?
- Did the RTC err post-Task Force report by refusing to dismiss despite findings of no violation?
- Did the RTC exceed its authority by ordering books inspection beyond the Task Force’s exclusive mandate?
- Did the RTC err in admitting Pasang Masda’s intervention without direct and immediate legal interest and beyond the allowed period?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)