Facts:
This case involves the challenge to Ordinance No. 4986 of the City of Manila and Administrative Orders No. 1 and No. 3, series of 1964, by the Public Service Commission (PSC) Commissioner Enrique Medina, which collectively applied traffic control measures affecting the operation of provincial buses in Manila. Petitioners were a mix of passengers from Cavite and Batangas, who depended on these buses for transportation, and public service operators whose operations were directly impacted by the contested measures.
Ordinance 4986 laid out specific routes and designated loading/unloading zones for provincial buses in Manila to mitigate traffic congestion. Administrative Order No. 1 mandated provincial buses to be clearly marked for “Provincial Operation” and restricted their operations within Manila, while Administrative Order No. 3 limited the number of provincial buses allowed into Manila, offering a concession to those operating within a 50km radius based on their business volume.
The petitioners contested the validity of these measures in original proceedings for certiorari and mandamus, arguing they were unconstitutional, illegal, and unjust. The Supreme Court had previously dealt with related issues in Lagman vs. City of Manila and Lagman vs. Medina, where the validity of similar restrictions was upheld. The current petitioners, however, raised additional points not specifically addressed in the previous cases.
Issues:
1. Whether the impugned Ordinance and Administrative Orders constitute an unconstitutional exercise of police power.
2. Whether the ordinance and orders unjustly discriminate against provincial buses as against other vehicles and infringe on the right to equal protection under the law.
3. Whether the petitioners possess vested rights that are impaired by the ordinance and orders.
Court’s Decision:
The Philippine Supreme Court denied the petition, upholding the validity of Ordinance No. 4986 and Administrative Orders No. 1 and No. 3. The Court ruled that:
– The measures were a legitimate exercise of police power, aimed at addressing traffic congestion and ensuring public welfare.
– No infringement of equal protection rights was found, as the classification between provincial and inter-urban buses was deemed reasonable based on their distinct characteristics and impact on traffic.
– Petitioners did not possess vested rights in their certificates of public convenience that could be infringed upon, as these are subject to the State’s regulatory powers.
Doctrine:
Certificates of public convenience confer no vested right immune to police power regulation aimed at promoting the general welfare.
Class Notes:
– Police power involves regulatory measures to promote public welfare, even at the expense of certain individual interests.
– Equal protection requires that laws apply to all members of a similar class equally, but allows for reasonable classification.
– Certificates of public convenience are privileges subject to the regulatory power of the state, and holders do not have an absolute right to operate free from new regulatory impositions.
Historical Background:
This case highlights the evolving regulatory landscape in Metropolitan Manila’s public transportation sector during a period of rapid urbanization and increasing vehicle population. It underscores the government’s continuing struggle to balance public welfare and the interests of public service operators amidst changing urban dynamics.
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