Case Digest (G.R. No. 131512) Core Legal Reasoning Model
Facts:
In Land Transportation Office v. City of Butuan (G.R. No. 131512, January 20, 2000), the Land Transportation Office (LTO), represented by Assistant Secretary Manuel F. Bruan, LTO Regional Office X Director Timoteo A. Garcia, and LTO Butuan Registrar Rosita G. Sadiaga, sought review of the Court of Appeals’ decision upholding a permanent injunction issued by the Regional Trial Court of Butuan (Branch 2). The injunction, granted on March 20, 1995, prohibited the LTO from (a) registering tricycles-for-hire and (b) issuing drivers’ licenses for tricycles, within Butuan City’s territorial limits, pursuant to Sangguniang Panglungsang Panlungsod Ordinance No. 916-92. That ordinance, passed on August 16, 1992, provided for the imposition of franchise fees, registration charges and driver’s permits for tricycles-for-hire. The City of Butuan, through Mayor Democrito D. Plaza II, maintained that under the 1987 Constitution and Republic Act No. 7160 (Local Government Code), all fees and li
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Case Digest (G.R. No. 131512) Expanded Legal Reasoning Model
Facts:
- Constitutional and Statutory Framework
- The 1987 Constitution (Art. X, Sec. 2) declares the policy that territorial and political subdivisions shall enjoy local autonomy.
- Republic Act No. 7160 (Local Government Code), effective 1 January 1992, aims to give local government units (LGUs) genuine and meaningful autonomy and delineates their powers, including:
- Section 129 – Power to create sources of revenue;
- Section 133(I) – Common limitation barring LGUs from levying fees for registration of motor vehicles and issuance of all kinds of driving licenses, “except tricycles.”
- Municipal Ordinance on Tricycles
- On 16 August 1992, the Sangguniang Panglungsod of Butuan passed Ordinance No. 916-92 (“An Ordinance Regulating the Operation of Tricycles-for-Hire”), providing for:
- Grant of franchises for tricycles-for-hire;
- Fees for registration of tricycles within Butuan City;
- Fees for issuance of driver’s permits for tricycles.
- Administrative Roles of National Agencies
- Department of Transportation and Communications (DOTC)
- Executes transportation laws and policies (Administrative Code, Book IV, Title XV, Ch. 1, Sec. 2).
- Land Transportation Office (LTO)
- A line agency under DOTC; empowered by R.A. 4136 (Land Transportation and Traffic Code) Art. III, Sec. 4(d)(1) to register all motor vehicles and license drivers;
- Custodian of all vehicle registration and driver license records.
- Land Transportation Franchising and Regulatory Board (LTFRB)
- Created by E.O. No. 202 (19 June 1987) under DOTC;
- Empowered by R.A. 4136, Sec. 5, to grant, regulate, suspend, or cancel franchises (Certificates of Public Convenience) for public land transportation, including tricycles-for-hire.
- Judicial Proceedings
- 28 June 1994 – City of Butuan filed a petition in RTC Branch 2 for prohibition, mandamus, and permanent injunction to declare Ordinance No. 916-92 valid and to prohibit LTO from registering tricycles or issuing tricycle driver’s licenses.
- 20 March 1995 – RTC issued a permanent writ of injunction prohibiting LTO from:
- Registering tricycles;
- Issuing licenses to tricycle drivers, recognizing City-issued registrations and permits valid within Butuan City limits.
- 17 November 1997 – Court of Appeals (CA) affirmed the RTC decision, dismissing LTO’s appeal.
- 2000 – LTO filed a petition for review on certiorari before the Supreme Court, contending that only franchising powers of the LTFRB were devolved to LGUs, not LTO’s registration and licensing functions.
Issues:
- Whether, under the Local Government Code and implementing guidelines, the powers of the LTO to register tricycles and issue driver’s licenses have been lawfully devolved to local government units, thereby validating City of Butuan Ordinance No. 916-92 and justifying the permanent injunction against LTO.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)