Case Digest (G.R. No. 157584) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Congressman Enrique T. Garcia of the 2nd District of Bataan v. The Executive Secretary et al. (G.R. No. 157584, April 2, 2009), petitioner Congressman Enrique T. Garcia, Jr. challenged the constitutionality of Section 19 of Republic Act No. 8479 (the Oil Deregulation Law of 1998), which provided for the removal of price controls on finished petroleum products five months after the law’s effectivity and authorized the President to accelerate deregulation under certain economic conditions. After the 1997 enactment of R.A. 8180 (Downstream Oil Industry Deregulation Act of 1996) was struck down in Tatad v. Secretary of Department of Energy for inhibiting fair competition, Congress enacted R.A. 8479 on February 10, 1998, excluding the invalidated provisions. Petitioner first sought nullification of Section 19 in Garcia v. Corona (G.R. No. 132451, 1999), but the Supreme Court denied relief, deeming the issue a political question. In the present certiorari petition under Rule 65, Ga Case Digest (G.R. No. 157584) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Pre-1998 Deregulation Efforts
- Republic Act No. 8180 (Downstream Oil Industry Deregulation Act of 1996) was enacted to remove price and non-price controls in the local downstream oil industry.
- In Tatad v. Secretary of DOE (Nov. 5, 1997), this Court struck down R.A. 8180 for containing provisions on tariff differentials, inventory requirements and predatory pricing that actually impeded fair competition and empowered an oligopoly (Petron, Shell, Caltex).
- Enactment of R.A. 8479 and Initial Challenge
- Congress responded by enacting Republic Act No. 8479 (Oil Deregulation Law of 1998) on February 10, 1998, excising the invalidated provisions.
- Section 19 of R.A. 8479 prescribed a five-month transition period before full deregulation and empowered the President to accelerate it under specified conditions.
- Congressman Enrique T. Garcia, Jr. filed Garcia v. Corona (Dec. 17, 1999), challenging the timing of full deregulation as opposed to its legality; the petition was dismissed as presenting a non-justiciable political question.
- Present Petition for Certiorari
- Petitioner again seeks to declare Section 19 unconstitutional, arguing (a) the “Big 3” oligopoly persists, (b) overpricing harms public interest, and (c) the Constitution mandates regulation/prohibition of monopolies.
- He contends res judicata does not apply because prior decisions did not resolve the merits and raises new evidence from price movements.
- Respondents invoke non-justiciability, separation of powers, and availability of anti-trust remedies under R.A. 8479.
Issues:
- Justiciability and Jurisdiction
- Does an actual case or controversy exist, or is the petition moot or academic?
- Does the challenge raise a political question beyond judicial review?
- Has petitioner satisfied standing, timeliness, and lis mota requirements for constitutional adjudication?
- Merits of Constitutional Challenge
- Whether Section 19 of R.A. 8479 violates Article XII, Section 19 of the Constitution by prematurely lifting price controls when an oil oligopoly allegedly persists.
- Whether Congress’s timing decision constitutes a “grave abuse of discretion” amounting to lack or excess of jurisdiction.
- Procedural Defenses
- Does res judicata bar relitigation of the same issue?
- Have alternative remedies (anti-trust safeguards under Sections 11–14 of R.A. 8479) been exhausted?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)