Case Digest (G.R. No. 179554) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In 1997, the Government, through the Department of Transportation and Communications, entered into a Build-Lease-Transfer (BLT) Agreement with Metro Rail Transit Corporation, Limited (MRTC) under R.A. 6957, granting MRTC ownership of the Metro Rail Transit 3 (MRT3) system for 25 years and the right to develop commercial premises or obtain advertising income from its structures. In 1998, Trackworks Rail Transit Advertising, Vending & Promotions, Inc. (Trackworks) contracted with MRTC and installed billboards, signages, and other advertising media within the interior and exterior of MRT3. In 2001, the Metropolitan Manila Development Authority (MMDA) promulgated Regulation No. 96-009, prohibiting the posting or display of any form of advertisement on public roads, sidewalks, parks, and open spaces, and directed Trackworks to dismantle its installations. When Trackworks refused, MMDA unilaterally removed the advertisements. On March 1, 2002, Trackworks filed Civil Case No. 68864 for Case Digest (G.R. No. 179554) Expanded Legal Reasoning Model
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)