Title
Metropolitan Manila Development Authority vs. Trackworks Rail Transit Advertising, Vending and Promotions, Inc.
Case
G.R. No. 179554
Decision Date
Dec 16, 2009
MMDA dismantled Trackworks’ MRT3 billboards citing regulation; Supreme Court upheld Trackworks’ rights, ruling MMDA lacked authority over private property under BLT agreement.

Case Digest (G.R. No. 179554)
Expanded Legal Reasoning Model

Facts:

  • Contractual and factual background
    • In 1997, the Department of Transportation and Communications (DOTC) entered into a Build-Lease-Transfer (BLT) agreement with Metro Rail Transit Corporation, Limited (MRTC) under Republic Act No. 6957, granting MRTC ownership of Metro Rail Transit 3 (MRT3) for 25 years and the right to develop commercial premises, lease or sublease the airspace above stations, and obtain advertising income.
    • In 1998, Trackworks Rail Transit Advertising, Vending & Promotions, Inc. (Trackworks) contracted with MRTC to install billboards, signages, and other advertising media on MRT3 structures.
  • Regulatory actions and procedural history
    • In 2001, MMDA issued Regulation No. 96-009 prohibiting any posting or installation of billboards, signs, posters, and other visual clutters on roads, sidewalks, center islands, parks, and open spaces. MMDA demanded that Trackworks dismantle its installations; upon refusal, MMDA unilaterally removed them.
    • On March 1, 2002, Trackworks sued MMDA in RTC Pasig (Civil Case No. 68864), obtaining a TRO on March 6 and a preliminary injunction on March 25, 2002, enjoining MMDA from dismantling its installations.
    • MMDA filed a certiorari/prohibition petition with the Court of Appeals (CA-SP No. 70932), which the CA denied on August 31, 2004; a motion for reconsideration was denied on March 14, 2005. The Supreme Court (SC) likewise denied MMDA’s petition for review (G.R. No. 167514) on October 25, 2005.
    • Meanwhile, on October 10, 2005, the RTC rendered a final decision permanently enjoining MMDA. MMDA’s appeal to the CA was denied on April 30, 2007, with reconsideration denied on September 3, 2007. MMDA filed the present petition for review before the SC (G.R. No. 179554), resolved December 16, 2009.

Issues:

  • Whether MMDA had the authority under its charter and existing regulations to dismantle, remove, or destroy Trackworks’ billboards, signages, and advertising media installed on MRT3 structures.
  • Whether MMDA Regulation No. 96-009, MMC Memorandum Circular No. 88-09, and the Building Code (PD 1096) apply to the private property of MRT3 under the BLT agreement.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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