G.R. No. 100481 - Philippine Interisland Shipping Association of the Philippines vs. Court of Appeals

The United Harbor Pilots’ Association of the Philippines, Inc. (UHPAP) and Manila Pilots’ Association (MPA) render compulsory pilotage services in Philippine ports.
The Philippine Ports Authority (PPA), created by P.D. No. 857, supervises and regulates pilotage and may “impose, fix, prescribe, increase or decrease” rates for port services.

On February 3, 1986, President Marcos issued EO 1088 increasing and unifying pilotage rates. The PPA refused to implement it and instead issued Memorandum Circular No. 43-86 with lower rates.
UHPAP sought a preliminary mandatory injunction in RTC-Manila (Civil Case No. 87-38913) to compel EO 1088’s enforcement and enjoin PPA sanctions; RTC granted a TRO and later ruled PPA must comply. PPA appealed to the Court of Appeals, which in October 1991 affirmed the RTC decision.

Proceedings on Administrative Order No. 02-88 and Contempt (G.R. Nos. 100481, 107720)

In February 1988, PPA issued AO 02-88 introducing an “open pilotage system” leaving rate-fixing to private contract; UHPAP and MPA filed certiorari in RTC-Manila (Civil Case No. 88-44726), and the court in October 1989 annulled AO 02-88 and made its preliminary injunction permanent.
The Court of Appeals dismissed the joint appeal of government and intervenors for lack of jurisdiction (purely legal issue). The Supreme Court later dismissed petitions for review on that ruling.
In July 1992 PPA issued AO 05-92 to assign and schedule pilots directly. UHPAP/MPA moved in October 1992 to cite PPA officials for contempt of the RTC’s injunction; RTC-Manila, Branch 2, issued orders restraining AO 05-92 and set contempt hearings, which PPA challenged.

Whether EO 1088 is a valid exercise of legislative power by the President and binding on PPA despite AO 02-88.
Whether the Court of Appeals erred in dismissing the appeal in G.R. No. 100481 for lack of jurisdiction.
Whether RTC-Manila, Branch 2 had jurisdiction to hear and decide contempt petitions arising from AO 05-92.