Title
Tatad vs. Secretary of the Department of Energy
Case
G.R. No. 124360
Decision Date
Nov 5, 1997
The Supreme Court ruled that provisions of R.A. No. 8180, including tariff differentials and deregulation mechanisms, violated the equal protection clause and perpetuated an oil industry oligopoly, rendering them unconstitutional.

Case Summary (G.R. No. 124360)

Petitioners and Respondents

G.R. No. 124360: Francisco S. Tatad vs. DOE Secretary & Finance Secretary, attacking Section 5(b) tariff differential.
G.R. No. 127867: Lagman, Arroyo, Garcia, Tanada, Flag, FDC, SANLAKAS vs. Executive Secretary, DOE Secretary, Caltex, Petron, Shell, contesting Section 15 on full deregulation timing, Section 6 inventory mandate, Section 9(b) predatory-pricing ban, and Executive Order No. 392.

Key Dates

• Enactment of R.A. 8180 – March 1996
• Transition phase begins – August 12, 1996
• Full deregulation under EO 392 – February 8, 1997
• Consolidated oral argument – September 30, 1997
• En banc decision – November 5, 1997

Applicable Law

1987 Philippine Constitution (post-1990 decision date basis).
R.A. 7638 (Department of Energy Act of 1992) and R.A. 8180 (Downstream Oil Industry Deregulation Act of 1996).
EO 172 (1987) creating the Energy Regulatory Board; EO 377 (1996) institutional framework; EO 392 (1997) full deregulation order.

Historical Regulation of the Oil Industry

Pre-1971 saw minimal intervention; the Oil Industry Commission Act (R.A. 6173) created the OIC with power to fix prices, licenses and operations. Presidential Decree 334 (1973) established PNOC; P.D. 1956 (1984) created the Oil Price Stabilization Fund. EO 172 (1987) formed the Energy Regulatory Board; R.A. 7638 (1992) created the DOE and mandated deregulation timetables.

Congress Deregulates in 1996

R.A. 8180 ended 26 years of regulation by liberalizing importation, refining, marketing, distribution and pricing of petroleum products. It phased out controls via a two-stage process: a transition (non-pricing controls and formula-based margins) and full deregulation (price controls lifted; OPSF abolished).

Challenge to Section 5(b) (G.R. 124360)

Section 5(b) imposed a 3% tariff on imported crude oil versus 7% on refined products until 2004, allegedly violating equal protection (barrier to new entrants relying on imports), overriding the single-subject rule and undermining deregulation’s goal of competition.

Challenge to Section 15 & EO 392 (G.R. 127867)

Section 15 delegated to the DOE Secretary and President the timing of full deregulation (“as far as practicable” when world crude prices “are declining” and the peso “is stable”). EO 392 advanced full deregulation to February 1997, citing OPSF depletion, stable oil prices and exchange rates. Petitioners argued undue legislative delegation, arbitrariness and creation of a de facto cartel.

Procedural Issues: Justiciability and Standing

The Court held that challenges to constitutionality are judicial, not political, questions. Petitioners possessed standing under the Court’s liberal doctrine given the public significance of oil regulation and their demonstrated legal injury or interest.

One-Subject/One-Title and Equal Protection (Section 5[b])

The 3%–7% tariff differential was deemed germane to deregulation’s objective of encouraging new refineries and thus complied with the Constitution’s one-subject rule. On equal protection, the differential was found a substantial barrier to new entrants and therefore inconsistent with Article XII, Section 19’s competition mandate.

Delegation and Contingent Legislation (Section 15 & EO 392)

Section 15 passed the completeness and sufficient standard tests: it fixed full deregulation by March 1997 with optional advancement when specified economic conditions obtain. EO 392 was declared ultra vires for considering OPSF depletion, a factor not authorized by the statute.

Competition Guarantees: Inventory and Predatory P

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