Case Digest (G.R. No. 242860) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In LTFRB v. Valenzuela and DBDOYC, Inc., petitioners the Land Transportation Franchising and Regulatory Board (LTFRB) and the Department of Transportation (DOTr), successors of the Department of Transportation and Communications (DOTC), issued Department Orders Nos. 2015-11 and 2017-11 defining and regulating Transportation Network Companies (TNC) and Transportation Network Vehicle Service (TNVS) as public transport classifications requiring Certificates of Public Convenience (CPC). On May 26, 2016, private respondent DBDOYC, Inc. registered with the SEC and launched the Angkas motorcycle-hailing app in December 2016 without obtaining LTFRB accreditation or CPCs. Despite a January 27, 2017 LTFRB press release warning against its illegal operation, Angkas continued to match riders and passengers for hire. On July 4, 2018, DBDOYC filed before the Regional Trial Court (RTC) of Mandaluyong City, Branch 213, a petition for declaratory relief with a temporary restraining order (TRO) a Case Digest (G.R. No. 242860) Expanded Legal Reasoning Model
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)