G.R. No. L-59234 September 30, 1982
TAXICAB OPERATORS OF METRO MANILA, INC., FELICISIMO CABIGAO and ACE TRANSPORTATION CORPORATION, petitioners, vs. THE BOARD OF TRANSPORTATION and THE DIRECTOR OF THE BUREAU OF LAND TRANSPORTATION, respondents.

FACTS

The Board of Transportation (BOT) issued Memorandum Circular No. 77-42, mandating the phased replacement of taxicabs over six years old, beginning with the phase-out of 1971 models in 1978. The Bureau of Land Transportation (BLT) issued Implementing Circular No. 52 to enforce this policy in Metro Manila. Petitioners, taxicab operators, sought to nullify these circulars before the BOT, arguing they would force the premature retirement of roadworthy vehicles, constituting a taking of property without due process and just compensation. After their administrative petition remained unresolved, petitioners filed this special civil action directly with the Supreme Court.
Petitioners contended the circulars were issued without the prior notice and hearing required by Presidential Decree No. 101, violating procedural due process. They further argued the circulars constituted an invalid exercise of police power for being oppressive, unreasonable, and discriminatory, as they applied only to taxis and not to other public utility vehicles, thereby infringing on the equal protection clause.

ISSUE

Whether Memorandum Circular Nos. 77-42 and 52 were issued in violation of constitutional rights to due process and equal protection of the law.

RULING

The Supreme Court dismissed the petition, upholding the validity of the assailed circulars. On procedural due process, the Court ruled that in the exercise of its quasi-legislative function, the BOT was not required to observe trial-type hearings prior to issuing general regulations like the phased replacement scheme. The essence of due process in administrative rule-making is satisfied by the opportunity to be heard subsequently, which petitioners availed of when they filed their administrative case with the BOT. Their failure to secure a resolution did not negate this opportunity.
On substantive grounds, the circulars were a valid exercise of the state’s police power to promote public safety and welfare. The Court held the six-year lifespan was a reasonable standard based on the BOT’s studies indicating operators recover costs and earn reasonable profits within that period. The classification limiting the phase-out to taxis in Metro Manila was based on substantial distinctions, as the government could address the most pressing public necessity—the prevalence of old and dilapidated taxis in the metropolitan area—as a priority. The equal protection clause does not forbid reasonable classification, and the circulars applied uniformly to all taxis within the defined class. The Court emphasized that police power regulations, when rationally connected to public comfort and safety, can permissibly affect property rights without constituting a compensable taking.