Case Digest (G.R. No. 57883) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 206486, the Republic of the Philippines, through the Department of Transportation and Communications (DOTC) and its Land Transportation Office (LTO), issued Department Order No. 2008-39 on October 6, 2008, revising fines and penalties for motor vehicle violations in Metro Manila. Published October 9 and 16, drivers Ribo D. Wayos and Timoteo B. Sarol, members of the Maria Basa Express Jeepney Operators and Drivers Association, were apprehended in Baguio City for “out of line” violations. Alleging that the Order delegated legislative power improperly and generated revenue rather than regulated traffic, Maria Basa’s President and the two drivers petitioned the Regional Trial Court (RTC), Branch 5, Baguio City (March 16, 2009). On May 2, 2012, the RTC declared D.O. 2008-39 unconstitutional and enjoined its implementation. The Office of the Solicitor General (OSG) moved for reconsideration (denied September 10, 2012) and filed a Rule 65 petition for certiorari before the Case Digest (G.R. No. 57883) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Consolidation of Cases
- Republic of the Philippines (through DOTC and LTO) filed G.R. No. 206486 to challenge the Court of Appeals’s dismissal of its Rule 65 certiorari petition and to set aside the RTC decision declaring DO 2008-39 unconstitutional.
- Angat Tsuper (G.R. No. 212604), Ximex (G.R. No. 212682), and NCTU (G.R. No. 212800) filed separate Rule 65 petitions to declare JAO 2014-01 unconstitutional and enjoin its enforcement.
- PISTON and PNTOA intervened in support of petitioners, likewise assailing JAO 2014-01.
- Antecedent Facts
- DO 2008-39 (Oct. 6, 2008) revised LTO fines and penalties for traffic and administrative violations; published Oct. 9 & 16, 2008.
- March 4, 2009: LTO officers apprehended Maria Basa jeepney drivers for “out-of-line” charges, applying DO 2008-39’s ₱6,000 fine.
- May 2, 2012: RTC declared DO 2008-39 null and void for being confiscatory and beyond LTO’s rule-making power; DO 2008-39 deemed a revenue measure.
- CA dismissed the OSG’s Rule 65 petition in Nov. 2012 and Mar. 2013 for being the wrong remedy; OSG elevated case to this Court under Rule 45.
- JAO 2014-01 (June 2, 2014; eff. June 19, 2014) superseded DO 2008-39 with higher fines and stiffer penalties after public consultations.
- All petitions were consolidated by Minute Resolutions in July 2014.
Issues:
- G.R. No. 206486
- Did the Court of Appeals err in dismissing the Rule 65 petition for being the wrong mode of appeal?
- Should DO 2008-39 be declared constitutional?
- G.R. Nos. 206486, 212604, 212682, 212800
- Were DO 2008-39 and JAO 2014-01 issued beyond delegated legislative power?
- Are they an invalid exercise of police power—oppressive, arbitrary, or confiscatory?
- Are they void for vagueness or overbreadth?
- Do they violate substantive due process?
- Do they infringe the equal protection clause?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)