G.R. No. 215650 , March 28, 2023
Augusto L. Syjuco, Jr., et al. vs. Joseph Emilio A. Abaya, et al.

FACTS

These consolidated petitions challenged the fare increases for the Light Rail Transit (LRT) and Metro Rail Transit (MRT) systems implemented by the Department of Transportation and Communications (DOTC) and related agencies in January 2015. The petitioners, including legislators, commuter groups, and advocacy organizations, argued that the increases were imposed without the requisite public notice and hearing, violating procedural due process and relevant administrative procedures. They contended that such rate-fixing exercises, while quasi-legislative in nature, directly affected public interest and thus demanded public participation. The respondents maintained that the fare adjustments were a valid exercise of their quasi-legislative power, asserting that notice and hearing were not mandatory for such acts absent a specific statutory requirement.
The core dispute centered on whether the administrative agencies’ act of setting new rail fares was subject to the notice and hearing requirements under the Administrative Code of 1987. The petitioners invoked the public’s right to be informed and heard on a matter of significant economic burden, while the respondents relied on the doctrine that quasi-legislative proceedings generally do not require trial-type hearings.

ISSUE

Whether the implementation of the LRT and MRT fare increases without prior public notice and hearing violated the constitutional right to due process and relevant administrative laws.

RULING

The Supreme Court, through the ponencia, granted the petitions. Justice Leonen, in his Separate Concurring Opinion, agreed with the disposition and elaborated on the jurisprudential foundations. The ruling clarified that while notice and hearing are not generally required for quasi-legislative acts, they become imperative when the law explicitly provides for them. The Administrative Code mandates public participation in the formulation of rules affecting public interest. Rate-fixing for public utilities like rail transport is a delegated legislative function that must be exercised within constitutional bounds.
Justice Leonen emphasized that due process under Article III, Section 1 of the Constitution is the overarching principle. The act of fixing rates, though discretionary and technical, must result in a just, reasonable, non-discriminatory, and non-confiscatory fare. The public, which bears the ultimate burden, must be furnished with a full explanation of the adjustment and the methodology used. They must be given a meaningful opportunity to be heard and to contest the increase. The absence of a reasonable explanation and a genuine dialogue transgresses the core of public participation mandated by law. The Court’s expanded judicial power under the 1987 Constitution allows it to review such acts for grave abuse of discretion, ensuring that administrative agencies do not act arbitrarily. The fare increase was invalidated due to this fatal procedural defect.