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Padua vs. Ranada

The Toll Regulatory Board (TRB) issued a resolution authorizing provisional toll rate adjustments on the Metro Manila Skyway. The resolution was published for three weeks but no hearing was conducted. Petitioners challenged the validity of the resolution on grounds of (a) violation of due process, (b) exorbitant toll rates, and (c) the resolution was authorized by the TRB Executive Director alone. The Supreme Court ruled that (a) due process was followed through publication, (b) determining appropriate toll rates is within TRB's expertise, and (c) the resolution was properly signed by TRB Directors even if they did not attend hearings, as agencies can delegate evidence gathering but must make independent judgments.

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83 views2 pages

Padua vs. Ranada

The Toll Regulatory Board (TRB) issued a resolution authorizing provisional toll rate adjustments on the Metro Manila Skyway. The resolution was published for three weeks but no hearing was conducted. Petitioners challenged the validity of the resolution on grounds of (a) violation of due process, (b) exorbitant toll rates, and (c) the resolution was authorized by the TRB Executive Director alone. The Supreme Court ruled that (a) due process was followed through publication, (b) determining appropriate toll rates is within TRB's expertise, and (c) the resolution was properly signed by TRB Directors even if they did not attend hearings, as agencies can delegate evidence gathering but must make independent judgments.

Uploaded by

michael jan de celis
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© © 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

Padua v. Ranada [G.R. No. 141949.

October
14, 2002]
08AUG
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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