G.R. No. 215650 , March 28, 2023
AUGUSTO L. SYJUCO, JR., PETITIONER, VS. JOSEPH EMILIO A. ABAYA, IN HIS CAPACITY AS SECRETARY OF THE DEPARTMENT OF TRANSPORTATION AND COMMUNICATIONS; HONORITO D. CHANECO, IN HIS CAPACITY AS ADMINISTRATOR OF LIGHT RAIL TRANSIT AUTHORITY; AND RENATO Z. SAN JOSE, IN HIS CAPACITY AS OFFICER-IN-CHARGE OF THE METRO RAIL TRANSPORT 3 OFFICE, RESPONDENTS.

(Consolidated with G.R. Nos. 215653, 215703, 215704, 216735)

FACTS

Petitioners assailed the constitutionality of Department of Transportation and Communications (DOTC) Department Order No. 2014-014 (D.O. No. 2014-014), which mandated the application of the “user-pays” principle and adopted a uniform base fare for the Light Rail Transit (LRT) Lines 1 and 2 and the Metro Rail Transit (MRT) Line 3 of PHP 11.00 plus PHP 1.00 per kilometer traveled. The order resulted in a 50 to 87% fare increase. Petitioners alleged that D.O. No. 2014-014 violated the due process clause as it was issued without prior notice and hearing, and that the increase was ruthless, arbitrary, and without basis. They sought to have the order struck down and its implementation enjoined.
The antecedents showed that the LRTA Board, to reduce government subsidy, conducted studies and provisionally approved a fare adjustment in January 2011, subject to public consultations held in February 2011. A report on these consultations was submitted. Subsequently, on December 18, 2014, then DOTC Secretary Joseph Emilio A. Abaya issued D.O. No. 2014-014, implementing the new fare structure effective January 4, 2015.

ISSUE

Whether D.O. No. 2014-014 is unconstitutional for having been issued without prior notice and hearing, in violation of the due process clause.

RULING

The Supreme Court GRANTED the petitions and declared D.O. No. 2014-014 NULL and VOID for having been issued with grave abuse of discretion amounting to lack or excess of jurisdiction.
The Court held that the doctrine in Vigan Electric Light Company, Inc. v. Public Service Commission—which dispenses with notice and hearing when an administrative body acts in a quasi-legislative capacity—does not apply when the law itself expressly provides the procedure for the validity of an administrative rule. In this case, Section 5 of Executive Order No. 202 (1987), which reorganized the DOTC, expressly requires that the DOTC, in the exercise of its power to fix rates, must consider the recommendations of the attached agency (the LRTA) and conduct public hearings. The LRTA’s own Charter (Executive Order No. 603) and its Revised Charter ( Republic Act No. 6957 ) require that fare rates be subject to public hearing. The Court found that while studies and a provisional approval occurred in 2011, the mandatory public hearing for the specific fare increase implemented by D.O. No. 2014-014 was not conducted. The “public consultation” held in 2011 was for a different, earlier proposal and could not satisfy the legal requirement for the 2014 order. Therefore, the issuance of D.O. No. 2014-014 without the required public hearing violated statutory due process and constituted grave abuse of discretion.
The Court did not rule on the substantive reasonableness of the fare increase, as the procedural flaw was sufficient to invalidate the order. It emphasized that the Court must apply the law as written when it expressly provides for procedures to be followed.