Alliance of Non-Life Insurance Workers v. Mendoza
REITERATIONFacts
The Antecedents: Petitioners, composed of various associations of non-life insurance workers, assailed Department of Transportation and Communications (DOTC) Department Order No. 2007-28, which integrated the issuance and payment of Compulsory Third Party Liability (CTPL) Insurance with the Land Transportation Office (LTO) IT System. The order aimed to eliminate fake CTPL insurance and streamline the registration process. Procedural History: Petitioners filed a Petition for Certiorari before the Court of Appeals (CA) assailing DO No. 2007-28. The CA dismissed their petition, finding forum shopping, prematurity, and lack of cause of action. The CA also noted that the remedy availed of was incorrect as DO No. 2007-28 was issued pursuant to DOTC's quasi-legislative powers, and the proper remedy was an appeal to the Office of the President. Petitioners then filed a Petition for Review on Certiorari before the Supreme Court. The Petition: Petitioners argued that the CA committed grave abuse of discretion and that its judgment was based on a misapprehension of facts. They contended that there was no forum shopping, that the doctrine of exhaustion of administrative remedies did not apply to quasi-legislative acts, and that DO No. 2007-28 was an ultra vires act. They also raised constitutional challenges. During the pendency of the case, the Department of Transportation (DOTr) issued Department Order No. 020-18, which revised the guidelines on mandatory insurance policies for motor vehicles. The Supreme Court noted this supervening event.
Issue(s)
Whether a petition for certiorari and prohibition is the correct remedy to assail a quasi-legislative act. Whether petitioners have legal standing to bring the petition. Whether the issuance of Department Order No. 020-18 mooted the petition. Whether petitioners are guilty of forum shopping.
Ruling
The Supreme Court denied the Petition. It held that the case was moot and academic due to the supervening issuance of DOTr Department Order No. 020-18, which impliedly repealed DOTC Department Order No. 2007-28. The Court also found that petitioners were guilty of willful and deliberate forum shopping, which warranted the dismissal of the petition and directed petitioners and their counsels to show cause why they should not be held in contempt.
Ratio Decidendi
On the propriety of the remedy: The Court affirmed that petitions for certiorari and prohibition are proper remedies to correct acts tainted with grave abuse of discretion, even those done in the exercise of quasi-legislative powers, citing Article VIII, Section 1 of the Constitution. The Court clarified that while the general rule for quasi-judicial acts requires exhaustion of administrative remedies, this doctrine does not apply to quasi-legislative acts. The DOTC's power to issue Department Order No. 2007-28 was derived from its quasi-legislative powers under Section 5 of Executive Order No. 125, as amended. On legal standing: The Court found that petitioners failed to establish their legal standing as associations suing on behalf of their members. While they presented Certificates of Incorporation, there was no showing that the associations were authorized by their members to file the petition, nor was there proof that their members were directly injured by the enactment of DO No. 2007-28. The Court reiterated the requirements for associations to have legal standing, including proof of authorization and direct injury to members, as established in cases like Provincial Bus Operators Association of the Philippines v. DOLE. On mootness: The Court ruled that the case was moot and academic due to the supervening issuance of DOTr Department Order No. 020-18 on August 24, 2018. This new order revised the guidelines on mandatory insurance policies and placed the determination of qualified insurers under the sole authority of the Insurance Commission, effectively repealing DO No. 2007-28. The Court noted that Section 9 of DO No. 020-18 contained a general repealing clause, and the provisions of the two department orders were irreconcilably inconsistent, leading to an implied repeal. On forum shopping: The Court agreed with the respondents that petitioners engaged in willful and deliberate forum shopping. The Court detailed how petitioners had filed multiple cases with similar issues and reliefs in different fora, including CA-G.R. SP No. 99791 and CA G.R. SP No. 99992, which were either withdrawn or dismissed. The Court found that petitioners admitted the commonality of their interests with other parties in related cases, such as PIRA in SCA Case No. 673. The Court emphasized that forum shopping is an act of malpractice that degrades the administration of justice and warrants summary dismissal of the cases and potential contempt charges.
Main Doctrine
A case becomes moot and academic due to supervening events, such as the issuance of a new department order that impliedly repeals the assailed issuance, rendering the issues no longer justiciable. Furthermore, deliberate forum shopping warrants the summary dismissal of the petition.