Title
Bonifacio Communications Corp. vs. National Telecommunications Commission
Case
G.R. No. 201944
Decision Date
Apr 19, 2023
BCC's exclusivity claim in BGC challenged by Innove; NTC upheld jurisdiction, enforcing competition in telecom services; SC affirmed, citing forum shopping.

Case Summary (G.R. No. 201944)

Petitioner(s)

BCC: Incorporated with BCDA, FBDC and Smart Communications, Inc. in 1997; its articles and shareholder agreement state it will own, construct, operate and maintain communications infrastructure in BGC and provide related services, including value‑added services (VAS), with certain exclusivity provisions in its agreements. PLDT: Acquired shares in SCI and FBDC by 2002, owning 75% of BCC through acquisition.

Respondent(s)

NTC: Issued Memorandum Circular No. 05‑05‑2002 and later administrative orders (October 28, 2008 and October 26, 2010) directing compliance with the circular and ordering petitioners to cease and desist from acts preventing Innove from implementing authorized telecommunications services in BGC. Innove: A telecommunications entity that secured NTC authorization and sought enforcement of its authorizations and of MC No. 05‑05‑02. FBDC: Developer and party to the MOA granting infrastructure rights.

Key Dates

  • October 16, 1997: Incorporation of BCC and execution of Shareholders’ Agreement.
  • 2002: PLDT acquired majority interest in BCC-related entities; May 13, 2002: NTC issued MC No. 05‑05‑2002.
  • September–October 2007–2008: Innove sought to install facilities; disputes arose; Innove filed Complaint before NTC (NTC Case No. 2008‑236).
  • October 28, 2008 & October 26, 2010: NTC orders challenged.
  • August 16, 2011 and May 18, 2012: Court of Appeals decisions denying certiorari and motion for reconsideration.
  • Supreme Court disposition as recited in the prompt.

Applicable Law and Authorities

  • 1987 Constitution (Article XII, Section 11) — prohibition on exclusive operation of public utilities.
  • Republic Act No. 7925 (Public Telecommunications Policy Act of 1995) and its IRR.
  • Executive Order No. 546 (creation and functions of the NTC).
  • NTC Memorandum Circular No. 05‑05‑2002.
  • NTC Rules (2006) governing practice and provisional remedies (cease and desist orders).
  • Relevant jurisprudence cited in the proceedings (e.g., prior decisions addressing NTC authority and exclusivity).

Facts

BCC was formed pursuant to a shareholders’ agreement and MOA granting it the right to install, own and maintain communications infrastructure in BGC and to provide related services, including VAS, with contractual provisions purporting to confer exclusivity in infrastructure and service provision. PLDT later acquired a 75% interest in entities connected to BCC. NTC issued MC No. 05‑05‑2002 declaring certain IT hub areas, including BGC, open to duly enfranchised public telecommunications entities (PTEs) for high‑speed networks and connectivity. Innove sought to install facilities in BGC and, in the course of doing so, replaced or connected to building conduit capacity previously associated with BCC. Innove petitioned the NTC to enforce MC No. 05‑05‑02 and obtain protection from alleged interference by BCC and PLDT.

Procedural History

Innove filed NTC Case No. 2008‑236 seeking enforcement of its authorizations and the NTC circular. NTC issued a cease‑and‑desist order (Oct. 28, 2008) directing petitioners to comply with MC No. 05‑05‑02 and to desist from acts preventing Innove from implementing authorized services; a subsequent NTC order denied reconsideration (Oct. 26, 2010). Petitioners filed civil actions in RTCs (specific performance, injunction and declaration of unconstitutionality of the NTC circular). Petitioners challenged the NTC orders via certiorari before the Court of Appeals, which denied relief (Aug. 16, 2011) and denied reconsideration (May 18, 2012). The Supreme Court review followed.

Issues Presented

  1. Whether the Court of Appeals correctly held that the NTC had jurisdiction over BCC. 2. Whether the CA correctly affirmed NTC orders directing compliance with MC No. 05‑05‑02 and ordering petitioners to cease acts preventing Innove from implementing services in BGC. 3. Whether petitioners were deprived of due process by alleged prejudgment based on an NTC letter to the DOJ. 4. Whether petitioners committed forum shopping by instituting parallel civil suits.

NTC Jurisdiction over BCC — Legal Basis and Court’s Reasoning

The Court sustained the CA’s conclusion that NTC may exercise jurisdiction over BCC to the extent that BCC’s activities fall within the NTC’s statutory and executive functions. The court relied on:

  • BCC’s own corporate documents and shareholder agreement admitting it would provide VAS and communications infrastructure; such admissions place at least some of its activities within regulatory scope.
  • EO No. 546 (Sec. 15) enumerating NTC functions, including issuance and enforcement of authorizations, prescribing areas of operation, establishing rules and standards related to CPCNs and supervising telecommunications facilities.
  • RA 7925 (Sec. 5) assigning NTC responsibilities to ensure quality, interconnection, fair market conduct, protection against misuse of monopoly powers, and other regulatory functions.
  • NTC Rules (2006) which permit complaints against holders of authorizations and persons operating services or possessing equipment with or without authority; the focus is on violations of NTC rules, authorizations, orders and decisions. The Court concluded NTC jurisdiction is not strictly limited to formally enfranchised PTEs but extends to persons whose activities affect enforcement of authorizations granted to PTEs, compliance with NTC rules, and public interest in telecommunications competition and access.

Validity and Enforcement of NTC MC No. 05‑05‑02 and the Cease‑and‑Desist Orders

The Court found MC No. 05‑05‑02 to be a valid exercise of NTC authority consistent with RA 7925 and EO 546. The circular declares BGC a free zone where duly enfranchised PTEs may provide high‑speed networks; the NTC’s issuance of cease‑and‑desist relief enforces compliance with that policy and protects authorized PTEs’ rights. The Court emphasized:

  • Innove held provisional NTC authorization to operate local exchange services; the NTC is empowered to ensure authorized PTEs can implement their authorizations and to require interconnection and non‑discriminatory access pursuant to RA 7925 and its IRR.
  • The NTC did not decide the constitutionality of the shareholder agreements or MOA but enforced the circular and Innove’s authorizations; by enforcing the circular the NTC effectively confirmed BGC as a free zone, rendering incompatible exclusivity provisions unenforceable against duly authorized PTEs.
  • Facilities essential to the provision of telecommunication services are integral to the public utility function; exclusivity over essential facilities and over public utility operation is proscribed by the Constitution (Art. XII, Sec. 11). Therefore, contractual exclusivity in infrastructure and services that interferes with PTE authorizations conflicts with constitutional and statutory policy and may be set aside by NTC enforcement actions.

Contractual Exclusivity, Constitutional Supremacy and Private Agreements

The Court reiterated that contractual stipulations that are contrary to law, public policy, or the Constitution are void. The Constitution forbids exclusive operation of public utilities; BCC/PLDT contractual arrangements purporting to grant exclusive rights to infrastructure and services in BGC were therefore unenforceable to the extent they conflict with constitutional and statutory mandates (RA 7925). The Court applied the doctrine that positive law and constitutional norms are deemed written into private contracts and may limit or nullify contractual exclusivities that impede the enforcement of PTE authorizations.

Cease‑and‑Desist as Provisional Relief and Requirement of Injunctive Equities

The Court found the NTC’s issuance of a cease‑and‑desist order proper under the NTC Rules (Sec. 4) as a provisional remedy to preserve public service and welfare pending final determination. Applying principles analogous to preliminary injunction analysis, the Court concluded:

  • Innove had a clear and unmistakable right to implement NTC‑granted authorizations; petitioners’ actions enforcing exclusivity threatened that right; the invasion was material and substantial; and there was u

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