Title
Roy III vs. Herbosa
Case
G.R. No. 207246
Decision Date
Nov 22, 2016
Petitioners challenged SEC-MC No. 8, alleging it violated the Gamboa Decision on 60-40 Filipino ownership in public utilities. Court upheld SEC-MC No. 8, citing consistency with Gamboa, lack of standing, and prematurity of PLDT compliance issue.

Case Summary (G.R. No. 248033)

Gamboa Decision and Resolution

The June 28, 2011 Decision held that “capital” refers only to voting shares—namely, common shares or any preferred shares entitled to vote—and that public utilities must ensure (1) full beneficial ownership of at least 60% of total outstanding capital stock and (2) 60% voting control by Filipinos. The October 9, 2012 Resolution affirmed that the 60–40 ownership requirement applies uniformly and separately to each class of shares, whether voting or non-voting, to guarantee effective Filipino control.

SEC Memorandum Circular No. 8

Issued May 20, 2013 by Chairperson Herbosa, MC No. 8 promulgated “Guidelines on Compliance with the Filipino-Foreign Ownership Requirements” for nationalized activities. Section 2 provides that the Filipino-ownership percentage shall be applied to both (a) the total number of voting shares and (b) the total number of all shares, voting or not.

Litigation History

Roy filed a Rule 65 petition on June 10, 2013 seeking to annul MC No. 8 for failing to require the 60–40 rule to each share class. Gamboa et al. intervened, mirroring Roy’s arguments. PLDT and the SEC filed comments opposing the petitions, arguing lack of standing, improper remedy, and that MC No. 8 faithfully implemented Gamboa. PSEI and SharePhil were later allowed to intervene and submitted comments on market impact and procedural propriety.

Procedural Challenges

The Court examined four requisites for judicial review: (1) actual case or controversy; (2) standing; (3) earliest opportunity to raise the constitutional question; and (4) lis mota. It found no actual controversy—Roy’s hypothetical examples lacked concrete facts—and held that Roy and Gamboa, et al. failed to allege personal, direct injury. Their asserted roles as citizens, lawyers, taxpayers, or PLDT subscribers did not satisfy locus standi. The petitions also violated the hierarchy of courts, as Rule 65 relief was available from lower tribunals. Finally, indispensable parties—other nationalized-industry corporations and their shareholders—were not impleaded.

Substantive Issue

The sole substantive issue was whether the SEC gravely abused its discretion in issuing MC No. 8. The Court concluded that MC No. 8 was fully consistent with the dispositive portions of Gamboa. Section 2 of MC No. 8 incorporated both the voting-rights test and the total-shares test required by Gamboa. Illustrative permutations showed that compliance with MC No. 8 necessarily ensured the 60–40 Filipino ownership rule over voting shares and full beneficial ownership of at least 60% of total capital stock.

Supreme Court Ruling

The Court held:
– The

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