Taxicab Operators of Metro Manila, Inc. vs. Board of Transportation, 117 SCRA 597

(Administrative  Law, reasonableness, quasi-judicial power)

Facts: Board of Transportation issued Memorandum Circular No. 77-42 providing for the phasing out and replacement of old and dilapidated taxis beyond 6 years old.

Pursuant to the BOT circular, the Bureau of Land Transportation issued Implementing Circular No. 52 instructing the implementation of said circular and formulating a schedule of phase-out of vehicles to be allowed and accepted for registration as public conveyances.

Petitioners seek to declare the nullity of the circulars on the ground that fixing the ceiling at 6 years is arbitrarily and oppressive because the road worthiness of taxicabs depends upon their kind of maintenance and the use to which they are subjected and therefore their actual physical condition should be taken into consideration at the time of the registration.

Issue: WON a circular phasing out taxicabs more than 6 years old is unreasonable and arbitrary.

Held: No. A reasonable standard must be adopted to apply to all vehicles uniformly, fairly and justly. The span of 6 yearsw supplies that reaonable standard. By the time taxis have fully depreciated, theircost recovered, and a fair return on investment obtained. Thyey are also generally dilapidated and no longer fit for safe and comfortable service to the public.

Taxicabs in Manila, compared to those in other places are subject to heavier traffic pressure and constant use.

 

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