G.R. No. 221190 , October 08, 2024
BAGONG ALYANSANG MAKABAYAN (BAYAN), ET AL., PETITIONERS, VS. HON. JOSEPH EMILIO A. ABAYA, ET AL., RESPONDENTS.

FACTS

Petitioners filed a Petition for Certiorari and Prohibition directly with the Supreme Court, assailing the validity of the Concession Agreement for the Manila Light Rail Transit 1 (LRT 1) Extension, Operations and Maintenance Project. The Agreement was executed on October 2, 2014, between the Department of Transportation and Communications (DOTC), the Light Rail Transit Authority (LRTA) (collectively, the grantors), and the Light Rail Manila Corporation (LRMC). The project involved extending LRT 1 to Bacoor, Cavite, and having LRMC operate and maintain the existing line for 32 years under the government’s Public-Private Partnership (PPP) program. The bidding process saw revisions after an initial failure, and ultimately, only LRMC submitted a bid proposal, which was accepted.
Petitioners alleged the Agreement’s execution involved grave abuse of discretion. They raised several constitutional and legal issues: (1) a violation of the right to information as they were refused copies of the Agreement and related documents; (2) a violation of due process as the Agreement allowed periodic fare adjustments without the notice and hearing required by the Public Service Law; (3) an infringement on the security of tenure of LRTA employees; (4) that the Agreement constituted an unauthorized franchise grant, as such power belongs solely to Congress and was not delegable by LRTA; and (5) that the Department of Transportation lacked the authority to grant such a franchise. Petitioners also contended the Agreement contained unconscionable stipulations, citing issues raised by the Commission on Audit and the Office of the Government Corporate Counsel regarding financial terms, including the balancing payment method and provisions on differential generation costs.

ISSUE

Whether the Supreme Court should take cognizance of the petition despite the petitioners’ direct resort to it, in light of the doctrine of hierarchy of courts and the nature of the issues raised.

RULING

The Supreme Court DISMISSED the petition for the petitioners’ failure to observe the doctrine of hierarchy of courts. The Court emphasized that its jurisdiction to issue writs of certiorari and prohibition is shared with the Regional Trial Courts and the Court of Appeals, and direct recourse to the Supreme Court is generally prohibited. Exceptions exist for “special and important reasons” or pure questions of law. The Court found that the petitioners did not sufficiently justify their direct filing. The issues raised were not purely legal, as they required a thorough examination of the Concession Agreement’s complex terms and the factual circumstances of its execution and implementation—matters better suited for trial courts. Furthermore, the petitioners failed to demonstrate the presence of “transcendental importance” or other compelling reasons to warrant an exception to the hierarchy rule. Consequently, the Court declined to rule on the substantive constitutional and legal challenges to the Concession Agreement.