G.R. No. L-53431 October 27, 1983
BOARD OF TRANSPORTATION, petitioner, vs. HONORABLE JOSE P. CASTRO and HONORABLE ERNANI CRUZ PAÑO, Presiding Judge, Br. IV and Executive Judge, respectively, of the Court of First Instance of Rizal (Quezon City), and GREATER MANILA FEDERATION OF JEEPNEY OPERATORS AND DRIVERS ASSOCIATION, INC., respondents.

FACTS

The Board of Transportation (BOT), upon the recommendation of the Minister of Transportation and Communications and subsequent approval by the President, decided to transfer its offices from Quezon City to Pasig, Metro Manila. The stated reasons were to secure its records from fixers, improve coordination with the Ministry, and occupy a purpose-built facility. The Greater Manila Federation of Jeepney Operators and Drivers Association, Inc. filed a petition for prohibition and/or injunction with the Court of First Instance of Rizal to prevent the transfer. The association argued the move was illegal, abusive, and would cause severe difficulties to its members due to travel bans and poor telephone service in Pasig. The Executive Judge issued a temporary restraining order enjoining the transfer.
The BOT filed a motion to dismiss, arguing the petition stated no cause of action as the association was not a “person aggrieved” suffering a legal wrong under Rule 65, but merely alleged inconveniences. Despite the BOT’s subsequent manifestations that the President had approved the transfer, a lease for the new building was executed, and its old premises had been leased to another agency, the presiding judge to whom the case was assigned failed to resolve the pending motions to dismiss and to lift the restraining order. This inaction prompted the BOT to file the present petition for mandamus and certiorari before the Supreme Court.

ISSUE

Whether the respondent judge committed grave abuse of discretion in failing to resolve the motions and in not dismissing the civil case, and whether the private respondent had a legal right to enjoin the transfer of the BOT offices.

RULING

The Supreme Court granted the petition, set aside the restraining order, and ordered the dismissal of the civil case. The Court held that the private respondent association had no cause of action. The determination of the BOT’s office location is a discretionary executive and administrative function, vested by law in the President. The Court emphasized that the President’s approval, based on factual considerations of efficiency and security, is not subject to judicial review absent a clear showing of arbitrariness or grave abuse of discretion, which was not present. The alleged hardships to the association’s members were mere inconveniences affecting only a segment of the public and did not constitute a legal wrong or violation of a specific right.
Furthermore, the Court ruled that the private respondent failed to exhaust administrative remedies. The association should have first elevated its grievance to the Ministry of Transportation and Communications and ultimately to the President before seeking judicial intervention. Since this plain and adequate remedy was not pursued, the action was premature and not ripe for judicial determination. Consequently, the respondent judge should have promptly dismissed the case. The judge’s inaction on the motions, which paralyzed a government agency’s operations to the detriment of public interest, constituted an unreasonable delay amounting to grave abuse of discretion.