Title
Land Transportation Franchising and Regulatory Board vs. Valenzuela
Case
G.R. No. 242860
Decision Date
Mar 11, 2019
DBDOYC operated Angkas, a motorcycle-hailing app, without LTFRB accreditation, claiming it wasn’t a public service; SC ruled it a common carrier subject to regulation, annulling the injunction.

Case Digest (G.R. No. 242860)
Expanded Legal Reasoning Model

Facts:

  • Regulatory Framework
    • On May 8, 2015, the DOTC issued Department Order (DO) 2015-11 amending DO 97-1097, creating two new classifications for public transport: Transportation Network Companies (TNC) and Transportation Network Vehicle Service (TNVS).
    • On June 19, 2017, DOTr issued DO 2017-11 defining TNVS and explicitly prohibiting motorcycles as public transport conveyances.
    • The LTFRB thereafter issued Memorandum Circulars governing accreditation of TNCs and the issuance of Certificates of Public Convenience (CPC) for TNVS, treating TNCs as transport providers and TNVS drivers as common carriers once online.
  • Angkas Operations
    • On May 26, 2016, DBDOYC, Inc. registered with the SEC and in December 2016 launched the Angkas app, pairing motorcycle drivers with passengers without securing LTFRB accreditation or CPCs.
    • On January 27, 2017, the LTFRB publicly warned that Angkas could not legally operate; despite this, DBDOYC continued operations without seeking accreditation.
  • RTC Proceedings
    • On July 4, 2018, DBDOYC filed a Petition for Declaratory Relief with application for TRO and writ of preliminary injunction before RTC-Mandaluyong, arguing (a) Angkas is not a public transport provider, (b) motorcycles are not prohibited under RA 4136 §7, and (c) LTFRB/DOTr lack jurisdiction over motorcycles for hire.
    • On July 13, 2018, the RTC issued a TRO finding DBDOYC’s business lawful. On August 20, 2018, the RTC granted a writ of preliminary injunction enjoining LTFRB and DOTr from regulating Angkas operations.
    • Petitioners filed a certiorari petition before the Supreme Court, which issued a TRO on December 5, 2018, restraining enforcement of the RTC’s injunction.

Issues:

  • Whether the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing a writ of preliminary injunction in favor of DBDOYC and against petitioners.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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