Case Digest (G.R. No. 196199)
Facts:
In Manila International Ports Terminal, Inc. v. Philippine Ports Authority (G.R. Nos. 196199 & 196252, December 7, 2021), the Philippine Ports Authority (PPA), a government corporation created under Presidential Decree No. 857, oversaw the Manila International Port Terminal Complex (MIPTC) in Tondo, Manila. On January 6, 1975, Presidential Decree No. 634 granted Manila International Ports Terminal, Inc. (MIPTI) a 25-year franchise to construct, operate, and maintain modern container terminals and related port facilities at North Harbor; this was amended on January 16, 1978 by Presidential Decree No. 1284 to clarify PPA’s power to audit and, if warranted, recommend revocation of MIPTI’s franchise. On April 1, 1980, MIPTI and PPA executed a Memorandum of Agreement prescribing operational rules, including PPA’s duty to conduct periodic inspections and, upon proper investigation or showing of violations, recommend suspension or revocation of the franchise. In June 1986, followingCase Digest (G.R. No. 196199)
Facts:
- Background
- PPA: Government corporation created by PD 857 (1975), vested with authority, control, and supervision over Manila International Port Terminal Complex (MIPTC) at North and South Harbors.
- MIPTI: Private domestic corporation granted a 25-year franchise under PD 634 (1975), amended by PD 1284 (1978); executed a 1980 MOA with PPA; subject to PPA inspections and audits under PD 1284 § 4(c) and MOA § 14.01.
- Events Leading to Take-Over (1986)
- April 2: PCGG sequesters MIPTI.
- June: PPA issues two letters warning MIPTI of alleged performance violations and urges corrective action.
- July 18: PPA GM Solis serves letter citing specific alleged illegal acts; orders MIPTI’s reply by next morning.
- July 19: MIPTI denies allegations; same day President issues EO 30 revoking franchise; PPA notifies its take-over plan.
- July 20: PPA grants Metrostar a 1-year permit to handle cargo at North Harbor.
- July 21: PPA seizes MIPTI equipment, transfers operations to Metrostar; joint inventory conducted.
- August 14: PPA offers to buy seized equipment at book value; MIPTI refuses; rentals secured via guarantee fund.
- Litigation and Lower Courts’ Rulings
- Sept 23, 1986: MIPTI sues PPA, PPA GM Solis, and Metrostar in RTC Manila for due process and contract-impairment violations; seeks restoration and damages.
- April 30, 2003 RTC Decision: EO 30 declared unconstitutional (no publication, no hearing); PPA take-over illegal; awards P180 M replacement cost (if return impossible), P1.5 M/month actual damages, P1.5 M/month rental, P200 K exemplary, P500 K attorney’s fees, 6% interest from July 19, 1986.
- Sept 22, 2010 CA Decision (CA-G.R. CV 80775): Affirms RTC as to due process and seizure; modifies damages to P19,049,710 fair value, P250,000/month lost profits; deletes rental award; keeps exemplary, attorney’s fees, costs; 6%→12% interest post-decision.
- Supreme Court Review
- MIPTI (G.R. 196199) and PPA (G.R. 196252) separately petition SC, challenging CA’s modifications.
- Central issues: validity of EO 30 and PPA’s seizure; proper measure of damages.
Issues:
- Whether EO 30’s revocation of MIPTI’s franchise violated due process?
- Whether PPA’s seizure of MIPTI’s equipment was valid under EO 30, PD 1284, and the MOA?
- Whether the awards for replacement cost, rentals, lost profits, exemplary damages, and attorney’s fees were proper?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)