NATIONAL
Advocates Philippines
SC Denies Bayyo Association's Challenge Against DOTr Department Order
In a recent decision led by Associate Justice Maria Filomena D. Singh, the Supreme Court En Banc has dismissed the petition for certiorari and prohibition filed by Bayyo Association, Inc. (Bayyo) and its President, Anselmo D. Perweg. The petition challenged the validity of the Department of Transportation's (DOTr) Department Order (DO) No. 2017-011, which outlines the implementation of the Public Utility Vehicle Modernization Program (PUVMP).
Bayyo, claiming to represent 430 jeepney operators and drivers in Metro Manila, contested the new vehicle specifications, franchise issuance procedures, and practices set by DO No. 2017-011 for various Public Utility Vehicles (PUVs).
The petitioners argued that the order constitutes an invalid delegation of legislative power and cited the unconstitutionality of paragraph 5.2 for allegedly violating due process and equal protection clauses.
However, the Supreme Court ruled against the petition, citing the petitioners' lack of legal standing and a violation of the principle of the hierarchy of courts. The Court emphasized that constitutional challenges require compliance with specific legal requisites, including the necessity for an actual case, standing to question the act, timely raising of constitutional issues, and making the constitutionality the central issue of the case.
The Court found that Bayyo failed to establish legal standing, as it did not provide sufficient proof that it is a legitimate association of PUJ operators and drivers. The absence of Bayyo's Articles of Incorporation and By-Laws, coupled with the failure to identify and authorize its members, led to the dismissal of the petition.
Moreover, the petitioners were found in violation of the principle of hierarchy of courts, as they failed to first bring the petition before the appropriate lower court, creating grounds for dismissal. The Supreme Court stressed that the doctrine of hierarchy of courts is a constitutional filtering mechanism designed to address fundamental legal tasks and ensure proper legal procedures.
The Court highlighted that the factual questions raised by the petitioners, such as the alleged confiscatory nature of DO No. 2017-011, its impact on PUJ operators and drivers, and the financial implications of the modernization program, should be addressed in the trial courts or the Court of Appeals, which are better equipped to handle factual issues.
In conclusion, the Supreme Court's decision reinforces the legal prerequisites for challenging government acts, emphasizing the importance of legal standing, adherence to the hierarchy of courts, and the proper forum for addressing factual questions related to constitutional challenges.
Bayyo, claiming to represent 430 jeepney operators and drivers in Metro Manila, contested the new vehicle specifications, franchise issuance procedures, and practices set by DO No. 2017-011 for various Public Utility Vehicles (PUVs).
The petitioners argued that the order constitutes an invalid delegation of legislative power and cited the unconstitutionality of paragraph 5.2 for allegedly violating due process and equal protection clauses.
However, the Supreme Court ruled against the petition, citing the petitioners' lack of legal standing and a violation of the principle of the hierarchy of courts. The Court emphasized that constitutional challenges require compliance with specific legal requisites, including the necessity for an actual case, standing to question the act, timely raising of constitutional issues, and making the constitutionality the central issue of the case.
The Court found that Bayyo failed to establish legal standing, as it did not provide sufficient proof that it is a legitimate association of PUJ operators and drivers. The absence of Bayyo's Articles of Incorporation and By-Laws, coupled with the failure to identify and authorize its members, led to the dismissal of the petition.
Moreover, the petitioners were found in violation of the principle of hierarchy of courts, as they failed to first bring the petition before the appropriate lower court, creating grounds for dismissal. The Supreme Court stressed that the doctrine of hierarchy of courts is a constitutional filtering mechanism designed to address fundamental legal tasks and ensure proper legal procedures.
The Court highlighted that the factual questions raised by the petitioners, such as the alleged confiscatory nature of DO No. 2017-011, its impact on PUJ operators and drivers, and the financial implications of the modernization program, should be addressed in the trial courts or the Court of Appeals, which are better equipped to handle factual issues.
In conclusion, the Supreme Court's decision reinforces the legal prerequisites for challenging government acts, emphasizing the importance of legal standing, adherence to the hierarchy of courts, and the proper forum for addressing factual questions related to constitutional challenges.
Mar 7, 2024
