G.R. No. 242860. March 11, 2019.
THE LAND TRANSPORTATION FRANCHISING AND REGULATORY BOARD (LTFRB) AND THE DEPARTMENT OF TRANSPORTATION (DOTR), PETITIONERS, VS. HON. CARLOS A. VALENZUELA, IN HIS CAPACITY AS PRESIDING JUDGE OF THE REGIONAL TRIAL COURT OF BRANCH 213, REGIONAL TRIAL COURT OF MANDALUYONG CITY AND DBDOYC, INC., RESPONDENTS.

FACTS

The Department of Transportation (DOTr) and its attached agency, the Land Transportation Franchising and Regulatory Board (LTFRB), issued Department Order (DO) 2017-11 and related memorandum circulars to regulate Transportation Network Companies (TNCs) and Transportation Network Vehicle Services (TNVS). These issuances explicitly prohibited motorcycles from being used as public transport conveyances. Private respondent DBDOYC, Inc., operator of the motorcycle-hailing mobile application “Angkas,” launched its service without obtaining the required TNC accreditation and TNVS Certificates of Public Convenience from the LTFRB.
DBDOYC filed a Petition for Declaratory Relief with an application for a preliminary injunction before the Regional Trial Court (RTC). It argued that it was merely a technology platform connecting passengers and drivers, not a public transportation provider subject to LTFRB regulation. It alternatively contended that DO 2017-11 was invalid for prohibiting motorcycles as public utility vehicles, contrary to the Land Transportation and Traffic Code. The RTC granted the application and issued a writ of preliminary injunction, enjoining the LTFRB and DOTr from interfering with Angkas’s operations, holding that DBDOYC had a clear constitutional right to pursue a lawful business not yet prohibited by statute.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in issuing the writ of preliminary injunction against the LTFRB and DOTr.

RULING

Yes, the Supreme Court granted the petition and nullified the RTC’s orders. The Court held that the RTC committed grave abuse of discretion. The legal logic is anchored on the principle that a writ of injunction cannot issue against acts performed by a government agency pursuant to its statutory mandate and validly issued regulations. The LTFRB, under its charter and the Public Service Act, has the explicit power and duty to regulate public land transportation, including the issuance of franchises. The DO 2017-11 and related LTFRB issuances, which classify and regulate TNCs and TNVS, are valid exercises of this quasi-legislative power and carry the presumption of legality. By operating Angkas without the required accreditation and permits, DBDOYC was violating these valid regulations.
The RTC’s finding of a “clear and unmistakable right” in favor of DBDOYC based on a constitutional right to liberty and enterprise was erroneous. No such right exists to operate a business in defiance of specific and valid regulatory requirements. The right to due process does not mean one can operate first and challenge the regulations later while continuing illegal operations. The LTFRB’s acts of warning and intending to apprehend illegal operators were in pursuit of a clear legal duty. Since the petitioners were acting within their legal authority, enjoining them would cause disorder and prejudice to public interest, which the writ of injunction is precisely designed to prevent. The RTC’s order effectively suspended the operation of a valid administrative regulation, which was a capricious and whimsical exercise of power constituting grave abuse of discretion.