Taxicab Operators v. Board of Transportation, 119 SCRA 597 (Case Digest)

 

Taxicab Operators v. Board of Transportation,

119 SCRA 597

Facts:

            The Bureau of Land Transportation issued memorandum for the “Phasing out and Replacement of Old and Dilapidated Taxis.” Herein petitioners filed a petition for Certiorari, Prohibition and mandamus with Preliminary Injunction and TRO against herein Respondents.

            Petitioners’ argued that the memorandum violate their constitutional rights to equal protection of the law and substantive due process.

 

Issue:

                Whether or not the petitioners’ constitutional rights to substantive due process were violated because they did not ever summoned to attend any conference prior to the issuance of the questioned BOT Circular.

 

Held:

                No.

 

Ratio:

                Previous notice and hearing as elements of due process, are constitutionally required for the protection of life or vested property rights, as well as of liberty, when its limitation or loss takes place in consequence of a judicial or quasi-judicial proceeding, generally dependent upon a past act or event which has to be established or ascertained. It is not essential to the validity of general rules or regulations promulgated to govern future conduct of a class or persons or enterprises, unless the law provides otherwise.

                The State, in the exercise, of its police power, can prescribe regulations to promote the health, morals, peace, good order, safety and general welfare of the people. It can prohibit all things hurtful to comfort, safety and welfare of society.  It may also regulate property rights.

 

Issue:

            Whether or not the constitutional rights of equal protection of the law of the petitioners had been violated.

 

Held:

            No.

 

Ratio:

            In so far as the non-application of the assailed Circulars to other transportation services is concerned, it need only be recalled that the equal protection clause does not imply that the same treatment be accorded all and sundry. It applies to things or persons Identically or similarly situated. It permits of classification of the object or subject of the law provided classification is reasonable or based on substantial distinction, which make for real differences, and that it must apply equally to each member of the class.  What is required under the equal protection clause is the uniform operation by legal means so that all persons under Identical or similar circumstance would be accorded the same treatment both in privilege conferred and the liabilities imposed.  The challenged Circulars satisfy the foregoing criteria.