Case Digest (G.R. No. 230107) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The consolidated petition involves Department of Transportation (DOTR), Maritime Industry Authority (MARINA), and Philippine Coast Guard (PCG) as petitioners and several shipping companies together with the Philippine Petroleum Sea Transport Association as respondents. On June 2, 2007, Republic Act No. 9483 (the Oil Pollution Compensation Act of 2007) was enacted to implement the 1992 Civil Liability and Fund Conventions, mandating in Section 22(a) the establishment of an Oil Pollution Management Fund (OPMF) funded initially by a ten-centavo per liter impost on oil delivery or transshipment by tanker barges and haulers. Its Implementing Rules and Regulations (IRR) were promulgated on April 12, 2016, formalizing the impost and vesting MARINA with trust-fund administration. A month later, respondents filed a Petition for Declaratory Relief with prayer for preliminary injunction before the Regional Trial Court (RTC) of Quezon City, Branch 216, assailing the constitutionality of Sec... Case Digest (G.R. No. 230107) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- The Case
- Petitioners: Department of Transportation (DOTR), Maritime Industry Authority (MARINA), Philippine Coast Guard (PCG)
- Respondents: Philippine Petroleum Sea Transport Association and eight shipping corporations
- Subject Matter: Constitutionality of establishing an Oil Pollution Management Fund (OPMF) under Section 22(a) of Republic Act No. 9483 and Section 1, Rule I of its Implementing Rules and Regulations (IRR), imposing a ten-centavo per liter impost on oil deliveries by tankers and barges
- Antecedents
- Marine Biodiversity and Oil Spill Disasters
- December 2005 Antique spill: 364,000 liters bunker oil, 40 km coastline polluted, 230 ha mangroves destroyed
- August 2006 Guimaras spill: 2.1 million liters, worst in Philippine history, 320 km coastline sludge, 1,100 ha marine sanctuaries damaged, 40,000 fishers affected
- Legislative Response
- Enactment of RA 9483 (Oil Pollution Compensation Act of 2007) to implement the 1992 Civil Liability and Fund Conventions
- Section 22(a): creation of OPMF with initial impost of ₱0.10 per liter; fund to be used for PCG clean-up operations (90%) and research/enforcement/monitoring (10%)
- April 12, 2016 IRR, Rule I: detailed provisions on establishment, sources, OPMF Committee, collection, disbursement, audit, and reporting
- Procedural History
- May 2016 Petition for Declaratory Relief (Rule 63) filed by respondents; RTC granted preliminary injunction (July 25, 2016)
- RTC Decision (February 22, 2017): declared Section 22(a) RA 9483 and Section 1, Rule I IRR unconstitutional (grounds: equal protection, due process, prohibited rider, undue delegation)
- Petitioners elevated the case to the Supreme Court via petition for review on certiorari
Issues:
- Are the assailed provisions properly justiciable and actionable under the Petition for Declaratory Relief?
- Do Section 22(a) of RA 9483 and Section 1, Rule I of the IRR amount to a prohibited rider?
- Does the classification of “owners and operators of oil tankers and barges” violate the equal protection clause?
- Is the ten-centavo per liter impost confiscatory and violative of the due process clause?
- Does delegating to the OPMF Committee the power to set future impost rates constitute an undue delegation of legislative power?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)