Title
Land Transportation Franchising and Regulatory Board vs. Stronghold Insurance Co., Inc.
Case
G.R. No. 200740
Decision Date
Oct 2, 2013
The case revolves around the exclusion of Stronghold Insurance Company from a bidding process conducted by the LTFRB, with the Supreme Court ruling that the LTFRB did not commit grave abuse of discretion in disqualifying the company and declaring the Matching Clause in the contract void.
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Case Digest (G.R. No. 200740)

Facts:

  • The case involves the Land Transportation Franchising and Regulatory Board (LTFRB) and Stronghold Insurance Company, Inc. (Stronghold).
  • LTFRB regulates franchises of land-based public utility vehicles and implemented the Passenger Personal Accident Insurance Program (Program).
  • The Program ensures operators of passenger public utility vehicles have accident insurance policies.
  • LTFRB accredited two groups of insurance providers through open bidding.
  • In 2005, LTFRB accredited Universal Transport Solutions, Inc. (UNITRANS), with Stronghold as the lead insurer.
  • The five-year contract, extended until November 2011, included a Matching Clause allowing accredited groups to match the best bid in future biddings.
  • Before the contract expired, LTFRB conducted three rounds of bidding for new insurance providers.
  • Stronghold participated but failed to qualify in the third round due to insufficient capitalization and fewer group members.
  • Stronghold sought a writ of prohibition from the Court of Appeals, arguing that the Third Reference's "per insurer" capitalization requirement violated its rights.
  • The Court of Appeals nullified the third round of bidding and enjoined LTFRB from enforcing the new contract until Stronghold could exercise its matching right.
  • LTFRB contested this decision, arguing that Stronghold's exclusion was due to non-compliance with the Third Reference and that the Matching Clause did not grant Stronghold the right to bypass new bidding terms.
  • The Supreme Court issued a temporary restraining order on the Court of Appeals' ruling.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court set aside the Court of Appeals' decision and made the temporary restraining order permanent.
  • The Supreme Court ruled that LTFRB did not commit grave abuse of discretion in disqualifying Str...(Unlock)

Ratio:

  • The Supreme Court held that the Court of Appeals erred in issuing the writ of prohibition.
  • The writ is applicable only when proceedings are conducted without or in excess of jurisdiction or with grave abuse of discretion.
  • The Court of Appeals failed to apply the rigorous standard of Rule 65, which corrects jurisdictional errors, not mere errors of judgment.
  • LTFRB's decision to adopt a "per insurer" capitalization requirement in the Third Reference was a proper exercise of its regulatory powers to ensure financially sound insurance pr...continue reading

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