Case Digest (G.R. No. 141949)
Facts:
Ceferino Padua v. Hon. Santiago Ranada, et al., G.R. No. 141949; Eduardo C. Zialcita v. Toll Regulatory Board, et al., G.R. No. 151108, October 14, 2002, Supreme Court Third Division, Sandoval‑Gutierrez, J., writing for the Court. The consolidated petitions challenge Toll Regulatory Board (TRB) Resolution No. 2001‑89, which the TRB issued on November 9, 2001, authorizing provisional toll rate adjustments for the Metro Manila Skyway, effective January 1, 2002. The Resolution set interim toll rates (including staged implementation), and the provisional increases were published December 17, 24 and 31, 2001.Tracing antecedent events: on February 27, 2001 Citra Metro Manila Tollways Corporation (CITRA) filed with the TRB an application for an interim adjustment of toll rates under the Supplemental Toll Operation Agreement (STOA) (Nov. 27, 1995), which allows an interim adjustment upon a "significant currency devaluation" and while financing remains outstanding. CITRA later filed an Urgent Motion for Provisional Approval (Oct. 9, 2001) invoking Section 3, Rule 10 of the TRB Rules of Procedure; it withdrew that motion (Oct. 30, 2001) yet requested the TRB to act promptly because of alleged imminent financial collapse of the Project and affected lenders. On November 9, 2001 the TRB granted provisional relief via Resolution No. 2001‑89.
Two parties separately sought court intervention. In G.R. No. 141949 petitioner Ceferino Padua (a toll payer) had an existing petition for mandamus to compel the RTC judge to issue a writ of execution enforcing an earlier Court of Appeals decision; he filed an Urgent Motion for a TRO to stop the toll increases, arguing lack of publication/due process, unauthorized action by the Executive Director alone, and CITRA's lack of standing. In G.R. No. 151108 petitioner Eduardo Zialcita (a taxpayer and congressman) filed a petition for prohibition (with prayer for TRO/PI), arguing the TRB acted without notice/hearing, violated P.D. No. 1112 and the Constitution, and that TRB Rule Section 3, Rule 10 is unauthorized.
Respondents (TRB, CITRA, Philippine National Construction Corporation (PNCC), Department of Public Works and Highways (DPWH), the Republic, and Judge Ranada) through the Office of the Solicitor General argued TRB's exclusive administrative jurisdiction over...(Pro-only)
Issues:
- Were the remedies employed by petitioners—an urgent motion for a TRO in G.R. No. 141949 and a petition for prohibition in G.R. No. 151108—procedurally proper to assail TRB Resolution No. 2001‑89?
- If procedurally reachable, did the TRB commit grave abuse of discretion or otherwise act unlawfully in issuing Resolution No. 2001‑89 (i.e., failure of publication, issuance by a single official, lack of standing by CITRA, improper scope, failure to state facts/law, or absence of authority ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)