G.R. No. 72119 - Legaspi vs. Civil Service Commission

Petitioners: Samson V. Pantaleon, Eduardo A. Tacoyo, Jr., Jesus S. Bautista and Monico C. Agustin—public utility bus drivers plying SM Fairview–Baclaran (and Novaliches–Baclaran) routes for 3–27 years.
Respondent: Metro Manila Development Authority (MMDA), an administrative agency created by R.A. 7924, governed by the Metro Manila Council (MMC), composed of the mayors of the cities and municipalities of Metro Manila and certain national‐agency representatives.

R.A. 7924 (1995) established MMDA with “planning, monitoring and coordinative functions” and “regulatory and supervisory authority” over metro-wide services, including traffic management, and empowered MMC to promulgate rules and regulations.
MMC Regulation No. 96-005 (May 31, 1996) introduced the Unified Vehicular Volume Reduction Program (UVVRP), or number coding scheme, prohibiting vehicles on certain days based on plate endings (1–2 Monday, 3–4 Tuesday, 5–6 Wednesday, 7–8 Thursday, 9–0 Friday), exempting ambulances, fire trucks, government vehicles, school buses; P300 fine per violation.
Memorandum of Agreement (July 15, 1996) between MMDA and bus operators associations partially exempted their buses from UVVRP, subject to revocation for rule violations or safety concerns.

MMC Resolution No. 10-16 (Oct 15, 2010): re-implemented UVVRP for all public utility buses (provincial and city) on an experimental basis from Nov 15, 2010 to Jan 15, 2011 due to heavy traffic and bus driver rule violations.
MMDA Memorandum Circular No. 08, Series of 2010 (Oct 27, 2010): amended Circular No. 04 (Revised Exemption Guidelines) to remove public utility buses from the exemption list; effective Nov 15, 2010.
Publication: Resolution No. 10-16 was published Oct 30, 2010 in Manila Standard and The Manila Times.

Petition for Injunction filed Nov 22, 2010, praying for temporary restraining order/status quo ante order and permanent injunction against enforcement of Resolution No. 10-16 and Circular No. 08, and declaration of nullity.
Respondent’s Comment filed Feb 10, 2011; Petitioners’ Reply filed Apr 14, 2011.
Petitioners argued MMDA exceeded its administrative powers under R.A. 7924, encroached on Land Transportation Franchising and Regulatory Board (LTFRB) powers under Commonwealth Act No. 146 and E.O. 202, violated E.O. 712 (DOTC approval), and denied due process by revoking hours and impairing livelihood.

Does the Supreme Court have original jurisdiction to entertain a petition for injunction under the Constitution and Rules of Court?

Do R.A. 7924 and MMC’s charter powers authorize MMDA Resolution No. 10-16 and Memorandum Circular No. 08, Series of 2010?

Do the MMDA issuances unlawfully encroach upon LTFRB’s exclusive jurisdiction to grant, amend, or revoke public utility franchises under Commonwealth Act No. 146, the Public Service Act, and E.O. 202 Sections 5(a)–(b)?

Are the bus drivers petitioners the real parties in interest with standing to challenge the revocation of the bus-operators’ exemption and franchise conditions?

Do the challenged issuances violate procedural or substantive due process under the Constitution by being promulgated without notice and hearing and by effectively reducing petitioners’ work hours and earnings?