Title
Office of the Solicitor General vs. Ayala Land, Inc.
Case
G.R. No. 177056
Decision Date
Sep 18, 2009
The OSG sought to enforce free parking in private malls under the National Building Code, but the Supreme Court ruled that the law does not mandate free parking, upholding lower courts' decisions.

Case Summary (G.R. No. 177056)

Factual Background: Mall Parking Facilities and Fees

Respondents operate shopping malls with on‑site parking facilities (owned, constructed, or leased). They incur construction, maintenance, security and administrative expenses for those facilities. Respondents uniformly charged parking fees to users (whether mall patrons or the general public) in specified schedules: Ayala Land (weekday and weekend rates), Robinsons (P20 for first three hours then P10/hour), Shangri‑La (flat P30/day), SM Prime (P10–P20 for first ~four hours then P10/hour). Parking tickets contained exculpatory clauses disclaiming liability for loss or damage.

Senate Investigation and Report (1999–2000)

Senate Committees on Trade and Commerce and Justice and Human Rights conducted hearings in 1999 on the legality and reasonableness of mall parking fees and the practice of exculpatory clauses. Senate Committee Report No. 225 (May 2, 2000) concluded that collection of parking fees by malls was contrary to the National Building Code and therefore illegal. The Report recommended that the OSG seek to enjoin fee collection and enforce penal provisions of the Code, that DTI and DPWH coordinate regulation, and that Congress amend the Code to expressly prohibit charging for parking and the use of waiver clauses.

Procedural Posture: Parallel RTC Actions

SM Prime filed a Rule 63 petition for declaratory relief (Civil Case No. 00‑1208) on October 3, 2000, challenging Rule XIX of the IRR as ultra vires and asserting a right to lease parking spaces. The OSG filed a petition for declaratory relief and injunction (Civil Case No. 00‑1210) on October 4, 2000, seeking to enjoin respondents from collecting parking fees and to declare the practice violative of the National Building Code. The two actions were consolidated by the RTC of Makati.

Issues Framed by the RTC

The RTC limited issues at pretrial to: (1) OSG’s capacity to sue and whether the parking fee controversy involved public welfare; (2) propriety of declaratory relief; (3) whether respondents are obligated to provide free parking; and (4) entitlement to damages.

RTC Findings and Ruling (May 29, 2002)

The RTC held that the OSG had capacity to sue and that the requisites for declaratory relief were satisfied. On the dispositive issue, the RTC concluded that neither the National Building Code (Section 803) nor Rule XIX of the IRR imposes an obligation to provide parking spaces free of charge. Article 1158 of the Civil Code was invoked to stress that obligations derived from law are not presumed and must be expressly provided. The RTC held that compelling free parking would constitute an unlawful taking of private property without just compensation and that parking provisions in the Code regulate occupancy/congestion and do not speak to fee collection. The RTC dismissed counterclaims and denied damages.

Court of Appeals Proceedings and Ruling (January 25, 2007)

The Court of Appeals initially agreed that the OSG’s appeal raised a pure question of law but nonetheless resolved the case on the merits because issues from SM Prime’s appeal warranted consideration. The appellate court affirmed the RTC on several points: the OSG’s capacity to sue, that exhaustion of administrative remedies was not required where the dispute was legal in character, and that the validity of the IRR need not be decided because it was not among agreed issues and the controversy could be resolved otherwise. Critically, the CA agreed that Section 803 and Rule XIX were intended to control occupancy and congestion and did not prescribe free parking; absent clear statutory or regulatory language, respondents could not be compelled to provide parking without charge. The CA denied the appeals and upheld the RTC decision in toto.

Supreme Court Issues Presented on Certiorari

The OSG moved for review before the Supreme Court, assigning a single error: that the Court of Appeals erred in affirming that respondents are not obliged to provide free parking spaces. The OSG argued that Section 803 and Rule XIX, read together with Section 102 (Declaration of Policy) of the National Building Code, authorize regulation to safeguard life, health, property and public welfare and thus justify requiring complimentary parking to reduce traffic congestion and protect ventilation and light standards.

Statutory Interpretation: Scope of Section 803, Rule XIX, and Section 102

The Supreme Court applied plain‑meaning principles: Section 803 and Rule XIX require minimum off‑street parking ratios (e.g., 1 slot/100 sq. m. for neighborhood shopping centers) but are silent on collection of parking fees. Section 102 sets forth policy objectives and the Code’s purpose to provide minimum standards for buildings’ location, design, use, and maintenance. The Court held that Section 102 does not constitute an open grant of regulatory power to regulate or prohibit fees beyond ensuring compliance with minimum building standards. Absent express statutory language, the Code and IRR cannot reasonably be read to mandate free parking.

Administrative Rule‑Making Limits

The Court reiterated the principle that administrative rules and implementing regulations must conform to and not extend the enabling statute. Agencies may issue rules implementing the statute’s details but cannot amend, expand or add substantive obligations not covered by the statute. Therefore, Rule XIX cannot be read to impose obligations (such as free parking) not authorized by PD 1096.

Police Power, Regulatory Fees, and the Limits of State Regulation

The OSG’s argument invoked police power to regulate privately owned parking to advance public welfare (e.g., reduce congestion). The Court noted that police power authorizes regulation and the imposition of regulatory fees but does not ordinarily empower the State to prohibit the owner from charging for use of private property in a way that amounts to confiscation. Regulatory measures that effectively deprive owners of profitable use of their property can constitute a taking.

Eminent Domain and Compensable Taking Analysis

The Court analyzed whether prohibiting parking fees would amount to a taking under eminent domain principles. It observed that regulation which deprives property owners of the profitable use of property may amount to a compensable taking unless the invasion is so slight as to be justified under police power. A blanket prohibition on charging for private parking would substantially intrude upon property rights: respondents would be deprived of the ability to recover construction and maintenan

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