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LTFRBANshow cause-FAILURE TO PROv-bicol-pacd-2025-38-cs-2-03-25

The document is an official response from Bicol Isarog Transport System regarding a complaint filed by Lovely Del Rosario for failure to provide adequate public transportation services. The respondent argues that the complaint lacks merit due to the absence of a verified complaint and that service disruptions were caused by Typhoon Kristine, which were beyond their control. The respondent requests the dismissal of the complaint and asserts compliance with all relevant laws and regulations.

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Christian Valencia
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42 views4 pages

LTFRBANshow cause-FAILURE TO PROv-bicol-pacd-2025-38-cs-2-03-25

The document is an official response from Bicol Isarog Transport System regarding a complaint filed by Lovely Del Rosario for failure to provide adequate public transportation services. The respondent argues that the complaint lacks merit due to the absence of a verified complaint and that service disruptions were caused by Typhoon Kristine, which were beyond their control. The respondent requests the dismissal of the complaint and asserts compliance with all relevant laws and regulations.

Uploaded by

Christian Valencia
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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REPUBLIC OF THE PHILIPPINES

Department of Transportation
LAND TRANSPORTATION FRANCHISING AND REGULATORY BOARD
East Avenue, Quezon City

LOVELY DEL ROSARIO, Case No. PACD-2025-38-CS


Complainant. For: Failure to Provide Safe, Adequate
Convenient, Environment Friendly and
-versus- Dependable Public Land Transportation
Services.

BICOL ISAROG TRANSPORT SYSTEM,


and Driver of PUB with Plate No. NONE.
Respondents.
x - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - x

ANSWER
COMES NOW, the Respondent-Operator, through its authorized
representative and unto this Honorable Board, most respectfully submits its
ANSWER to the SHOW CAUSE ORDER :

1. That Respondent-Operator received a copy of the Show Cause Order


dated November 26, 2024 , hereby ordered to explain why its Certificate of Public
Convenience issued should not be SUSPENDED or CANCELLED for the alleged
above-mentioned violation/s involving one of its authorized units and to submit a
notarized Answer to the Honorable Board;

2. That “NO VERIFIED COMPLAINT” was filed by the Complainant as


required under the 2011 Revised Rules of Practice and Procedure before the Land
Transportation Franchising and Regulatory Board (LTFRB), which warrants an
outright dismissal for failure to comply to the procedural requirement;

3. That the Complaint for “Failure to provide safe, adequate,


comfortable and dependable Public Land Transportation Service “ has no basis
as the cancellation of trips were beyond the control of the respondent-operator
brought about by Typhoon Kristine which cancelled all trips between October 23
and 28, 2024;

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SPECIAL AND AFFIRMATIVE DEFENSES
That Respondent-Operator Repleads and Incorporates Paragraphs 1, 2,
and 3 by way of reference, in so far as they are relevant thereto, and further
alleges:
4. That there is no cause of action against the Respondent-Operator;
5. That as admitted by the Complainant, the cancellation of the trip was
caused by Typhoon Kristine. Rebooking of tickets will take a while because those
with prior bookings will also be affected. Respondent-Operator welcomes
rebooking and or refund but it should go by the process to be fair with the
respondent. Both parties were affected by the effects of the typhoon, which is
beyond anybody’s control. What the Respondent is asking from the complainant is
understanding and due consideration;
6. That Respondent does not Withhold or refused refund and or
rebooking as a policy especially if the reason is valid under the instant case,
however it should observe the process and procedures, which complainant
refused to accept and understand and instead is demanding for an instant refund
or rebooking;

7. That the drivers/conductors of the Respondent-Operator passed to a


rigid, meticulous training and evaluation during the recruitment period supported
by Police and NBI Clearances and Certification of good health, physical and mental
fitness to qualify before being allowed for duty, a proof that Respondent-
Operator exercised due diligence in the selection and supervision of its
employees;

8. That Respondent-Operator did not defy any existing laws, rules and
regulations enforced by the Honorable Board. Respondent-Operator has its own
set of company’s rules and regulations which provides appropriate penalty and
will be applied against the erring employee after an investigation and will be
reprimanded with stern warnings either by Suspension and or Termination from
service if warranted under the situation;

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9. That the Respondent-Operator is compliant to all laws, rules, and
regulations enforced by the Honorable Board in the operation of its transport
business and has not violated any of the terms and conditions of its Certificate of
Public Convenience granted by the Honorable Board;
WHEREFORE, in the interest of Public Service, it is most respectfully moved
and prayed for that the foregoing ANSWER be admitted and made parts of the
records of this case and that the complaint be Dismissed for lack of merit.
Other reliefs and remedies available in the premises are likewise prayed
for.
Quezon City, February 03, 2025.

CHRISTIAN G. VALENCIA
Authorized Representative
BICOL ISAROG TRANSPORT SYSTEM INC.
96 Mirasol St., 20th Avenue, Brgy. San Roque,
Cubao, Quezon City

VERIFICATION/CERTIFICATION

I, CHRISTIAN G. VALENCIA, Filipino, of legal age , after having been duly


sworn to in accordance with law hereby depose and say:
That I am the Authorized Representative of the Respondent-Operator in
the above-entitled case;
That I have caused the preparation of the foregoing ANSWER ;
That I have read and understood the contents thereof and the same are
true and correct to the best of my personal knowledge.
IN WITNESS WHEREOF, I have hereunto affixed my signature this
_____day of ________.

CHRISTIAN G. VALENCIA
Affiant

SUBSCRIBED AND SWORN TO BEFORE ME this ___ day of _____, 2025,


affiant exhibited to me his Driver’s License ID bearing No. E04-15-005588 as his
competent evidence of identity and affirming under oath the truthfulness of this
document.

NOTARY PUBLIC
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Doc. No. _____;
Page No. ______;
Book No. ______;
Series of 2025.

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