Title
Laguna Tayabas Bus Co. vs. Province of Laguna
Case
G.R. No. L-6976
Decision Date
Aug 30, 1955
Province of Laguna collected toll fees for Lumban Bridge pre-1949, upheld by Supreme Court; plaintiff denied refund for pre-reduction period.
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Case Summary (G.R. No. L-6976)

Background of the Case

  • The Laguna Tayabas Bus Company sought to recover toll fees amounting to P53,657.75, which it claimed were illegally collected by the Province of Laguna for the use of the Lumban bridge from February 26, 1948, to July 31, 1949.
  • The alternative prayer was for a refund of 50% of the toll fees paid during the same period, totaling P26,828.87.
  • The Court of First Instance of Laguna upheld the validity of the toll fee collection and dismissed the complaint, leading to the appeal.

Construction and Ownership of the Lumban Bridge

  • The Lumban bridge was constructed by the Province of Laguna in 1930 using funds from a bond issue.
  • The bridge was destroyed during World War II, leaving only the abutments and piers.
  • The national government agreed to construct a bailey bridge using the existing structures, following representations made by Congressman Estanislao Fernandez.

Toll Fee Collection and Resolutions

  • On October 1, 1947, the Provincial Board of Laguna approved Resolution No. 750, fixing toll fees for the bridge, which was subsequently approved by the Secretary of Public Works and Communications.
  • The bus company requested a revival of a pre-war discount arrangement, leading to Resolution No. 820 on November 5, 1947, which granted a 25% reduction.
  • The Department of Public Works and Communications later recommended a 50% reduction, which was approved on April 21, 1948, but the Provincial Board declined to implement it due to financial concerns.

Transition of Ownership and Toll Fee Adjustments

  • The Secretary of Public Works and Communications informed the Secretary of Interior about the ownership dispute and the refusal of the Provincial Board to adopt reduced toll rates.
  • After further correspondence, the Provincial Board approved Resolution No. 556 on August 3, 1949, agreeing to turn over the bridge to the national government and implement the reduced toll fees effective August 1, 1949.

Legal Issues Presented

  • The appeal raised two primary issues:
    1. The validity of toll fee collections made under Resolution No. 750 prior to the bridge's declaration as a national bridge.
    2. The entitlement of the plaintiff to a refund of toll fees paid during the disputed period.

Validity of Toll Fee Collection

  • The court acknowledged that the Lumban bridge was declared a national bridge on August 7, 1952, but the declaration was effective only from August 1, 1949.
  • The toll fees collected prior to this date were deemed valid as they were collected under the authority of the Secretary of Public Works and Communications and in compliance with Section 2131 of the Revised Administrative Code.

Implications of Executive Order No. 552

  • The court concluded that the col...continue reading

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