Case Digest (G.R. No. L-59234) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Taxicab Operators of Metro Manila, Inc., Felicisimo Cabigao and Ace Transportation Corporation (collectively, “TOMMI” or “petitioners”), domestic entities holding Certificates of Public Convenience for taxi operations in Metro Manila and adjacent Luzon provinces, filed a petition with the Board of Transportation (BOT) under Presidential Decree No. 101 seeking to annul BOT Memorandum Circular No. 77-42 (October 10, 1977) and Bureau of Land Transportation (BLT) Implementing Circular No. 52 (August 15, 1980). Memorandum Circular No. 77-42 mandated the phase-out of taxis older than six years to ensure public safety and comfort, while Circular No. 52 enforced this rule by refusing registration to units beyond six years of age. In response, petitioners lodged administrative proceedings before the BOT (docketed as Case No. 80-7553), presented documentary and testimonial evidence, and repeatedly urged resolution of their petition to forestall the phase-out of their 1974 model cabs. A Case Digest (G.R. No. L-59234) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Background
- Petitioners: Taxicab Operators of Metro Manila, Inc. (TOMMI), Felicisimo Cabigao, and Ace Transportation Corporation—grantees of Certificates of Public Convenience to operate taxicabs within Metro Manila and Luzon.
- Respondents: The Board of Transportation (BOT) and the Director of the Bureau of Land Transportation (BLT).
- Issuance of Administrative Circulars
- BOT Memorandum Circular No. 77-42 (October 10, 1977): mandated a six-year maximum service life for taxis, ordering the phased withdrawal of models 1971 and earlier by December 31, 1977, models 1972 by December 31, 1978, and so on.
- BLT Implementing Circular No. 52 (August 15, 1980): directed refusal of registration for taxi units over six years old in the National Capital Region and prescribed an automatic phase-out schedule.
- Proceedings Before the BOT
- January 27, 1981: Petitioners filed Case No. 80-7553 seeking nullification or suspension of MC No. 77-42 and permission to register roadworthy older model taxis.
- February–March 1981: Hearing held on February 20; petitioners offered evidence and submitted additional documents on March 27; no resolution issued; petitioners’ follow-ups failed as records were reportedly lost.
- Petition to the Supreme Court
- December 29, 1981: Petition for certiorari, prohibition, and mandamus filed in this Court challenging the legality of the two circulars.
- Issues raised: compliance with procedural due process under PD 101; violations of equal protection, substantive due process, and protection against arbitrary classification.
Issues:
- Procedural Due Process
- Whether BOT and BLT complied with the procedural requirements of Presidential Decree No. 101 in issuing the memoranda, particularly as to notice, hearing, and opportunity to submit position papers or attend conferences.
- Substantive Constitutional Rights
- Whether the six-year phase-out rule infringes petitioners’ rights to substantive due process and protection against arbitrary/unreasonable classification.
- Whether the circulars violate equal protection by applying initially only to Metro Manila and exclusively to the taxi industry.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)