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16 - MMDA vs. Viron Transportation Co., Inv 530 SCRA 95, 102

This case involves a petition for declaratory relief filed by Viron Transport Co. regarding an order by the Metropolitan Manila Development Authority (MMDA) to close provincial bus terminals along major roads in Metro Manila to ease traffic congestion. The President issued an executive order tasking the MMDA to implement measures to address traffic issues. The MMDA then recommended eliminating bus terminals and providing mass transit facilities. Viron Transport alleged the MMDA order would effectively close its bus terminals. The court ruled the case presented a justiciable controversy allowing for declaratory relief, as there was an actual dispute between parties over a legal interest that was ripe for determination.

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103 views2 pages

16 - MMDA vs. Viron Transportation Co., Inv 530 SCRA 95, 102

This case involves a petition for declaratory relief filed by Viron Transport Co. regarding an order by the Metropolitan Manila Development Authority (MMDA) to close provincial bus terminals along major roads in Metro Manila to ease traffic congestion. The President issued an executive order tasking the MMDA to implement measures to address traffic issues. The MMDA then recommended eliminating bus terminals and providing mass transit facilities. Viron Transport alleged the MMDA order would effectively close its bus terminals. The court ruled the case presented a justiciable controversy allowing for declaratory relief, as there was an actual dispute between parties over a legal interest that was ripe for determination.

Uploaded by

Kathleen Joy Garcia
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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MMDA vs. Viron Transportation Co.

, Inv 530 SCRA 95, 102

FACTS

The present petition for review on certiorari, rooted in the traffic congestion problem, questions the
authority of the Metropolitan Manila Development Authority (MMDA) to order the closure of provincial
bus terminals along EDSA and major thoroughfares of Metro Manila.

President Gloria Macapagal Arroyo issued E.O. 179 on February 10, 2003, "Providing for the
Establishment of Greater Manila Mass Transport System” wherein MMDA is tasked to undertake
measures to ease traffic congestion in Metro Manila and ensure the convenient and efficient travel of
commuters within its jurisdiction. The MMDA had "recommended a plan to decongest traffic by
eliminating the bus terminals now located along major Metro Manila thoroughfares and providing more
and convenient access to the mass transport system to the commuting public through the provision of
mass transport terminal facilities". The E.O. thus designated the MMDA as the implementing agency for
the Project.

On February 24, 2003, Viron Transport Co., Inc. (Viron), a domestic corporation engaged in the business
of public transportation with a provincial bus operation, filed a petition for declaratory relief alleging
that the MMDA, through Chairman Fernando, was "poised to issue a Circular, Memorandum or Order
closing, or tantamount to closing, all provincial bus terminals along EDSA and in the whole of the
Metropolis under the pretext of traffic regulation." This impending move, it stressed, would mean the
closure of its bus terminal in Sampaloc, Manila and two others in Quezon City. The trial court sustained
the constitutionality and legality of the E.O. pursuant to R.A. No. 7924, which empowered the MMDA to
administer Metro Manila’s basic services including those of transport and traffic management

ISSUE

W/N the case presents a justiciable controversy, allowing for a petition for declaratory relief.

RULING

Yes. The following are the essential requisites for a declaratory relief petition: (a) there must be a
justiciable controversy; (b) the controversy must be between persons whose interests are adverse; (c)
the party seeking declaratory relief must have a legal interest in the controversy; and (d) the issue
invoked must be ripe for judicial determination. The requirement of the presence of a justiciable
controversy is satisfied when an actual controversy or the ripening seeds thereof exist between the
parties, all of whom are sui juris and before the court, and the declaration sought will help in ending the
controversy. A question becomes justiciable when it is translated into a claim of right which is actually
contested.

In the present cases, respondents’ resort to court was prompted by the issuance of the E.O. Section 2 of
the E.O. thereafter lays down the immediate establishment of common bus terminals for north- and
south-bound commuters. And the E.O. was made effective immediately. The MMDA’s resolve to
immediately implement the Project, its denials to the contrary notwithstanding, is also evident from
telltale circumstances, foremost of which was the passage by the MMC of Resolution No. 03-07, Series
of 2003 expressing its full support of the immediate implementation of the Project. It cannot be gainsaid
that the E.O. would have an adverse effect on respondents. The closure of their bus terminals would
mean, among other things, the loss of income from the operation and/or rentals of stalls thereat.
Precisely, respondents claim a deprivation of their constitutional right to property without due process
of law.

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