Case Digest (G.R. No. 218245) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 24, 2016, Steelasia Manufacturing Corporation, a local producer of steel bars, filed a petition for declaratory relief with the Regional Trial Court (RTC), Br. 142, Makati City (Civil Case No. R-MKT-16-00874-SC), against the Department of Trade and Industry (DTI), its Bureau of Product Standards (BPS), and the Bureau of Customs (BOC). SteelAsia sought to nullify Department Administrative Order No. 5, Series of 2008 (DAO No. 5) and its Implementing Rules and Regulations (IRR), and Department Administrative Order No. 15-01, Series of 2015 (DAO No. 15-01). These issuances allowed the *conditional release* of imported merchandise from BOC custody pending compliance with testing, inspection, and certification requirements mandated by Republic Act No. 4109 (RA 4109) and Republic Act No. 7394 (RA 7394). SteelAsia argued that the DAOs conflicted with RA 4109’s command that testing precede any release and violated the Equal Protection Clause by treating importers more favorably t Case Digest (G.R. No. 218245) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners: Department of Trade and Industry (DTI) and Bureau of Product Standards (BPS).
- Respondent: SteelAsia Manufacturing Corporation.
- SteelAsia sought declaratory relief to nullify:
- DTI Department Order No. 5, Series of 2008 and its Implementing Rules and Regulations (IRR).
- DTI Department Administrative Order No. 15-01, Series of 2015.
- SteelAsia’s Contentions
- DAOs conflict with Republic Act No. 4109 (RA 4109): testing, inspection, and certification must precede any release of imports.
- DAOs violate equal protection: imported goods may obtain conditional release pending compliance, local manufacturers may not.
- Regional Trial Court Ruling
- Decision dated November 10, 2017: Declared the DAOs ultra vires and of no force and effect; held testing must precede release.
- Order dated March 23, 2018: Denied SteelAsia’s motion for reconsideration.
- Supreme Court Appeal
- Petitioners invoked certiorari to reverse and set aside the RTC dispositions.
- Solicitor General’s arguments:
- DAOs merely allow physical transfer from Bureau of Customs (BOC) premises to secure warehouses pending testing.
- Rule-making power granted under EO No. 293, RA 7394 (Consumer Act), and RA 4109.
Issues:
- Remedy
- Is a petition for declaratory relief proper to assail the validity of the DTI Regulations?
- Statutory Conflict
- Are the DAOs in conflict with RA 4109 and RA 7394, thus invalid?
- Promulgation Defect
- Are the DAOs defective for not being jointly promulgated with the Commissioner of Customs?
- Equal Protection
- Do the DAOs violate the equal protection clause by favoring importers over local manufacturers?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)