**Facts:**
– **June 24, 2016:** SteelAsia Manufacturing Corporation (Steelasia) files a petition for declaratory relief to nullify DTI Department Administrative Orders (DAO) No. 5, series of 2008; its Implementing Rules and Regulations (IRR); and DAO No. 15-01, series of 2015.
– **Contention:** Steelasia contends these regulations allow the conditional release of imported merchandise from Bureau of Customs (BOC) premises prior to compliance with the required testing, inspection, and clearance in contravention of Republic Act No. 4109 (RA 4109).
– **Conflict Alleged:** The conditional release is in conflict with Section 3 and Section 6 of RA 4109 which mandates inspection and certification before any commodity is discharged or released by the BOC.
– **September 16, 2016:** The Department of Trade and Industry (DTI), represented by the Office of the Solicitor General (OSG), defends the regulations stating that the congestion in BOC premises necessitates conditional releases for efficient testing and inspection. They argue that the conditional release is followed by stringent control measures ensuring compliance with the required standards.
– **Procedural History:** The Regional Trial Court (RTC) of Makati City ruled in favor of Steelasia, declaring the DTI regulations ultra vires and void. The court emphasized that inspection must precede release to ensure compliance with standards and did not find sufficient ground to equate imported goods provisions with those applicable to local manufacturers.
– **November 14, 2018:** Steelasia reiterates opposition to the DTI claim, underscores alleged inconsistencies with RA 4109, and challenges the regulations’ applicability regarding locally manufactured and imported steel bars.
**Issues:**
1. **Proper Remedy:** Whether declaratory relief is an appropriate mechanism to challenge the validity of the DTI regulations.
2. **Statutory Conflict:** Whether DTI regulations contradict RA 4109 based on requirements for testing, inspection, and certification before the release of merchandise.
3. **Administrative Requirements:** Whether the regulations, crafted solely by the DTI and without the collaboration of the Commissioner of Customs, are defective.
4. **Equal Protection Clause:** Whether the DTI regulations violate the equal protection clause by providing different standards for imported and locally manufactured products.
**Court’s Decision:**
1. **Declaratory Relief as Remedy:**
– **Improper Remedy:** Declaratory relief is suitable only when no breach has yet occurred. Since Steelasia alleged an ongoing constitutional violation, certiorari was the appropriate remedy.
– **Public Implication and Certiorari Treatment:** Given the broad public implications, the Court treated the case as certiorari to provide comprehensive resolution.
2. **Statutory Conflict and Harmonization:**
– **No Conflict Found:** The Court held that RA 4109 and RA 7394 complemented each other requiring prior inspection and certification but did not preclude conditional release for storage pending testing.
– **Procedural Validity:** The DTI’s procedures for conditional release, including safeguards for storage and testing, met legislative intent ensuring efficient administration without compromising product standards.
3. **Administrative Requirements:**
– **Joint Promulgation Non-requirement:** The Court found that DTI regulations, although not jointly promulgated with the Commissioner of Customs, were valid. The requirement for joint regulations applied only to situations where imported products required modification to meet standards, not conditional release for storage.
4. **Equal Protection Clause:**
– **Valid Classification:** Differences in treatment between imported and locally manufactured products were found rational based on logistics and regulatory efficacy.
– **Four-Part Test Met:** The classification was reasonable, germane to legislative intent, applied equally within each category, and not confined to current conditions.
**Doctrine:**
– **In Pari Materia:** Statutes on the same subject must be construed together. RA 4109 and RA 7394 jointly enforced consumer protection through prior testing and certification for both locally produced and imported goods.
– **Reasonable Classification:** Equal protection allows for distinctions when logically and legally justified, particularly when dealing with imported versus domestically produced goods.
**Class Notes:**
– **RA 4109:** Requires testing, inspection, and certification before release of imported goods.
– **RA 7394 (Consumer Act):** Complements RA 4109, mandates consumer product standards.
– **Delegation Doctrine:** The power to create detailed regulations is vested in specialized administrative bodies (DTI) when guided by clear standards.
– **Equal Protection:** Requires substantive distinctions, aligned legislative goals, and consistent application.
**Historical Background:**
– **Economic Impact and Regulatory Evolution:** The case highlights the evolving complexity of trade regulations amidst increasing global trade, logistical challenges, and the need for adaptive administrative rules ensuring both economic efficiency and compliance with safety standards.
**Conclusion:**
The Supreme Court reversed the RTC decision, upholding the validity of the DTI regulations under the doctrines of statutory interpretation, appropriate procedural adaptation to factual realities, and reasonable regulatory classifications.
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