Case Summary (G.R. No. 218593)
Background of the Case
The petitioner filed a Petition for Injunction against the City of Mandaluyong, seeking to ensure its members' right to pass through the road under the flyover, based on their certificates of public convenience. The group asserted that city traffic enforcers were prohibiting their drivers from using this route and were issuing violation receipts for various infractions. The petitioner argued that there was no existing ordinance explicitly barring the use of the route.
Local Government Regulations
In response, the City of Mandaluyong cited Ordinance No. 358 (Series of 2005), which established the authority of the Traffic and Parking Management Office to regulate public utility jeepneys and buses. According to the ordinance, vehicles were prohibited from loading and unloading in specific congested areas, including under the Shaw Boulevard-EDSA crossing.
Court Decisions
The Regional Trial Court denied the petitioner's request for a temporary restraining order and a writ of preliminary injunction, determining that the petitioner did not possess a clear legal right to access the route in question. The Court emphasized the validity of the Traffic Management Code, stating that allowing unauthorized loading and unloading could harm public interest despite the absence of an explicit ordinance prohibiting such actions.
The Court of Appeals upheld this decision, affirming that local governments have the delegated power to establish traffic rules to alleviate congestion and ensure public order. This led to the present Petition for Review by the petitioner.
Legal Principles on Injunction
The issuance of an injunction requires the establishment of two conditions: the existence of a legal right to be protected and evidence that the actions sought to be restrained violate that right. The petitioner argued that its certificates of public convenience granted unequivocal rights to use the route, while the respondents maintained that the regulatory power of the city supersedes those certificates, which are inherently licenses subject to public good considerations.
Nature of Certificates of Public Convenience
The Supreme Court reiterated that certificates of public convenience are not vested property rights; rather, they are permits that grant the privilege to operate public transportation services under prescribed conditions. Consequently, the petitioner could not claim an absolute right to operate unconditionally under the traffic regulations set forth by the City of Mandaluyong.
Local Government's Exercise of Police Power
Local government units are endowed with the authority to regulate traffic through laws that aim to serve the general welfare. The court recognized that the need for
...continue readingCase Syllabus (G.R. No. 218593)
Case Overview
- This case involves a petition for review regarding the denial of a Petition for Injunction filed by Bagong Repormang Samahan ng mga Tsuper at Operator sa Rotang Pasig Quiapo via Palengke San Joaquin Ikot, Inc. (petitioner) against the City of Mandaluyong and its officials (respondents).
- The petitioner sought to enforce its members' right to passage under the Shaw Boulevard-EDSA flyover, claiming that the City of Mandaluyong violated their certificates of public convenience.
- The Regional Trial Court and the Court of Appeals both denied the petition for injunction, leading to this appeal.
Background of the Case
- The petitioner, represented by its President Cornelio R. Sadsad, Jr., claimed that its members were prohibited from passing under the Shaw Boulevard-EDSA flyover, where they typically loaded and unloaded passengers.
- The prohibition was enforced by local traffic enforcers who issued violation receipts for various offenses, despite no ordinance explicitly barring their passage.
- The City of Mandaluyong invoked Ordinance No. 358, Series of 2005, which authorized adjustments to the routes and terminals of public utility vehicles to manage traffic congestion.
Legal Issues
- The case primarily addresses whether the petitioner possesses a clear legal right to operate under the Shaw Boulevard-EDSA flyover and whether the City of Mandaluyong's actions constituted a violation of that right.
- The co