GR 206159; (August, 2020) (Digest)
G.R. No. 206159 , August 26, 2020
ALLIANCE OF NON-LIFE INSURANCE WORKERS OF THE PHILIPPINES, ET AL., PETITIONERS, VS. HON. LEANDRO R. MENDOZA, ET AL., RESPONDENTS.
FACTS
Petitioners, labor organizations representing non-life insurance workers, assailed the validity of Department of Transportation and Communications (DOTC) Department Order No. 2007-28. This order established an “Integrated CTPL Insurance Program,” mandating that Compulsory Third Party Liability (CTPL) insurance be automatically issued and paid for during motor vehicle registration at the Land Transportation Office (LTO). The system was to be integrated with the LTO Information Technology Project operated by respondent Stradcom Corporation, which was entitled to collect an “Interconnectivity Fee” for each policy issued.
Petitioners argued that the order was unconstitutional and void for allegedly delegating legislative power to a private entity (Stradcom), violating the non-impairment clause, and infringing upon the workers’ right to livelihood. They contended it created an illegal monopoly and was issued with grave abuse of discretion. The Court of Appeals dismissed their petition, prompting this appeal to the Supreme Court.
ISSUE
Whether the Petition has been rendered moot and academic by the issuance of a subsequent department order.
RULING
Yes, the Petition is moot and academic. During the pendency of this case, the Department of Transportation (DOTr) issued Department Order No. 020-18, entitled “Revised Guidelines on Mandatory Insurance Policies for Motor Vehicles.” This new order expressly revoked and superseded the challenged Department Order No. 2007-28. Section 9 of the new order contains a repealing clause stating that all prior inconsistent issuances are superseded.
The Court emphasized that a case becomes moot when there is no more actual controversy between the parties or when the issues have ceased to exist. The enactment of a superseding regulation which repeals the earlier regulation subject of the court action renders the case moot. Here, DO No. 020-18 fundamentally altered the regulatory landscape by removing the LTO’s and Stradcom’s roles in the integrated issuance system and placing the authority to determine qualified insurers solely with the Insurance Commission. Since the specific regulatory framework petitioners sought to nullify no longer exists, a ruling on its validity would be of no practical legal effect. The Court, therefore, declined to rule on the substantive constitutional issues raised, as doing so would only result in an advisory opinion on a defunct regulation. The Petition was dismissed on the ground of mootness.