Case Digest (G.R. No. L-6976)
Facts:
The case involves the Laguna Tayabas Bus Company as the plaintiff and appellant, and the Province of Laguna and its Provincial Treasurer as the defendants and appellees. The dispute centers around the collection of toll fees for the use of the Lumban Bridge, which the plaintiff claims were illegally collected from February 26, 1948, to July 31, 1949. The plaintiff seeks to recover a total of P53,657.75 or, alternatively, a refund of 50% of the toll fees paid during that period, amounting to P26,828.87. The Lumban Bridge was originally constructed by the Province of Laguna in 1930 using funds raised through bonds. After being destroyed during World War II, a bailey bridge was constructed with the assistance of the national government. On October 1, 1947, the Provincial Board of Laguna approved Resolution No. 750, which fixed the toll fees for the bridge, and this was subsequently approved by the Secretary of Public Works and Communications. The plaintiff had requested a discou...
Case Digest (G.R. No. L-6976)
Facts:
Construction and Ownership of the Lumban Bridge
- In 1930, the Province of Laguna constructed the Lumban Bridge using funds raised through a bond issue under its liability.
- The bridge was built on a portion of the Calamba-Sta. Cruz-Famy junction road, which was declared a national road by the Chief Executive (Executive Order No. 71, series of 1936, as amended by Executive Order No. 311, series of 1940).
- During World War II, the bridge was destroyed, leaving only the concrete abutments and middle piers.
Reconstruction and Toll Fees
- Congressman Estanislao Fernandez requested the national government to assist in reconstructing the bridge, as the province was financially unable to do so.
- The national government agreed and constructed a bailey bridge using the remaining structures of the old bridge.
- On October 1, 1947, the Provincial Board of Laguna approved Resolution No. 750, fixing toll fees for the use of the bailey bridge. This resolution was approved by the Secretary of Public Works and Communications under Section 2131 of the Revised Administrative Code.
Dispute Over Toll Fees
- The Laguna Tayabas Bus Company (plaintiff) requested a revival of a pre-war arrangement where it would receive a 40% discount on toll fees in exchange for an advance deposit.
- The Provincial Board granted a 25% reduction, but the Department of Public Works and Communications rejected this as discriminatory.
- The Director of Public Works recommended a 50% reduction, which was approved by the Secretary of Public Works and Communications on April 21, 1948.
- The Province of Laguna refused to implement the reduced toll rates, citing financial obligations from the bond issue and concerns over the national government's claim of ownership.
Ownership Dispute and Resolution
- The Secretary of Public Works and Communications declared the bridge to be national property, and the Province of Laguna was asked to adopt the reduced toll rates.
- On August 3, 1949, the Provincial Board of Laguna approved Resolution No. 556, turning over the bridge to the national government and making the reduced toll rates effective as of August 1, 1949.
- The President of the Philippines issued Executive Order No. 552 on August 7, 1952, declaring the bridge national and confirming the reduced toll rates effective August 1, 1949.
Plaintiff's Claim
- The plaintiff sought a refund of P53,657.75, representing 50% of the toll fees paid from February 26, 1948, to July 31, 1949, arguing that the reduced rates should have been applied retroactively.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Validity of Toll Fee Collection: The collection of toll fees by the Province of Laguna prior to August 1, 1949, was valid. The national government allowed the province to collect toll fees to help pay its bonded indebtedness. The bridge was only officially declared national property on August 7, 1952, with the reduced toll rates made effective as of August 1, 1949. The collection of toll fees before this date was in compliance with Section 2131 of the Revised Administrative Code.
No Retroactive Application of Reduced Rates: The reduced toll rates recommended by the Director of Public Works were not intended to apply retroactively. Executive Order No. 552 explicitly made the reduced rates effective only as of August 1, 1949. Therefore, the plaintiff was not entitled to a refund of the toll fees paid before this date.
Conclusion:
The Supreme Court affirmed the decision of the lower court, holding that the toll fees collected by the Province of Laguna before August 1, 1949, were valid and legal. The plaintiff's claim for a refund was denied. Costs were awarded against the appellant.