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Padua v. Ranada

The Toll Regulatory Board issued a resolution authorizing provisional toll rate adjustments on the Metro Manila Skyway. Petitioners challenged the resolution's validity on three grounds: (1) it violated due process since no hearing was conducted; (2) the toll increases were exorbitant and oppressive; and (3) the resolution was authorized by the TRB Executive Director alone. The Supreme Court ruled that (1) publication requirements were met so due process was satisfied; (2) determining appropriate toll rates was within the TRB's expertise; and (3) while no board members attended the hearing, the resolution was still signed by four directors in accordance with administrative procedures.

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29 views2 pages

Padua v. Ranada

The Toll Regulatory Board issued a resolution authorizing provisional toll rate adjustments on the Metro Manila Skyway. Petitioners challenged the resolution's validity on three grounds: (1) it violated due process since no hearing was conducted; (2) the toll increases were exorbitant and oppressive; and (3) the resolution was authorized by the TRB Executive Director alone. The Supreme Court ruled that (1) publication requirements were met so due process was satisfied; (2) determining appropriate toll rates was within the TRB's expertise; and (3) while no board members attended the hearing, the resolution was still signed by four directors in accordance with administrative procedures.

Uploaded by

Durch Haliya
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© © All Rights Reserved
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Padua v.

Ranada

FACTS

Toll Regulatory Board (TRB) issued Resolution No. 2001-89 authorizing provisional toll rate
adjustments on Metro Manila Skyway. It was thereafter published in newspapers of general
circulation for three (3) consecutive weeks. However, there was no hearing conducted for the
matter. Deliberations were not even attended by Board Members except TRB Executive Director
Jaime Dumlao, Jr. Petitioners assail the validity of the resolution.

ISSUES

Whether or not Resolution No. 2001-89 is invalid on the ground that:

(a) it was in violation of due process;


(b) the provisional toll rate adjustments are exorbitant, oppressive, onerous and
unconscionable; and,
(c) TRB Executive Director Jaime Dumlao, Jr. alone authorized the provisional increase.
RULING

“(a) No. TRB clearly complied with the publication requirements. Also, the TRB may grant and
issue ex-parte to any petitioner, without need of notice, publication or hearing, provisional
authority to collect, pending hearing and decision on the merits of the petition, the increase in
rates prayed for or such lesser amount as the TRB may in its discretion provisionally grant.

“(b) No. This is obviously a question of fact requiring knowledge of the formula used and the
factors considered in determining the assailed rates. Definitely, this task is within the province
of the TRB. The SC takes cognizance of the wealth of jurisprudence on the doctrine of primary
administrative jurisdiction and exhaustion of administrative remedies. In this era of clogged
court dockets, the need for specialized administrative boards or commissions with the special
knowledge, experience and capability to hear and determine promptly disputes on technical
matters or intricate questions of facts, subject to judicial review in case of grave abuse of
discretion, is indispensable. Between the power lodged in an administrative body and a court,
the unmistakable trend is to refer it to the former.”

“(c) No. It is not true that it was TRB Executive Director Dumlao, Jr. alone who issued
Resolution No. 2001-89. The Resolution itself contains the signature of the four TRB Directors.
Petitioner Padua would argue that while these Directors signed the Resolution, none of them
personally attended the hearing. This argument is misplaced. Under our jurisprudence, an
administrative agency may employ other persons, such as a hearing officer, examiner or
investigator, to receive evidence, conduct hearing and make reports, on the basis of which the
agency shall render its decision. Such a procedure is a practical necessity. Corollarily, in a
catena of cases, the Supreme Court laid down the cardinal requirements of due process in
administrative proceedings, one of which is that “the tribunal or body or any of its judges must
act on its or his own independent consideration of the law and facts of the controversy, and not
simply accept the views of a subordinate.” Thus, it is logical to say that this mandate was
rendered precisely to ensure that in cases where the hearing or reception of evidence is
assigned to a subordinate, the body or agency shall not merely rely on his recommendation but
instead shall personally weigh and assess the evidence which the said subordinate has
gathered.”

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