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RENATO C. CORONA v. UNITED HARBOR PILOTS ASSOCIATION OF PHILIPPINES

FACTS:

The Philippine Ports Authority (PPA) issued Administrative Order No. 04-92 (PPA-AO No. 04-92) on July 15, 1992, which limited the term of appointment of harbor pilots to one year subject to yearly renewal or cancellation. The PPA argued that this administrative order was issued in the exercise of its administrative control and supervision over harbor pilots under the law. The respondents, United Harbor Pilots Association and Manila Pilots Association, questioned the validity of PPA-AO No. 04-92 before the Department of Transportation and Communication (DOTC) but were informed that reviewing or annulling PPA's administrative issuances was within the jurisdiction of the PPA Board of Directors. The respondents appealed to the Office of the President (OP), but their appeal was dismissed and the restraining order previously issued was lifted. The respondents then filed a petition before the Regional Trial Court (RTC) of Manila, seeking to declare PPA-AO No. 04-92 null and void. The RTC ruled in favor of the respondents, declaring PPA-AO No. 04-92 and its implementing circulars null and void, and permanently enjoining its implementation.

ISSUES:

  1. Whether the Philippine Ports Authority (PPA) violated respondents' right to exercise their profession and their right to due process law by issuing Administrative Order No. 04-92, which limited the term of appointment of harbor pilots to one year subject to yearly renewal or cancellation.

RULING:

  1. Yes, the PPA violated respondents' right to exercise their profession and their right to due process law. The Court ruled that PPA-AO No. 04-92 unduly restricts the right of harbor pilots to enjoy their profession before their compulsory retirement. The issuance was found to be unreasonable and in stark disregard of respondents' right against deprivation of property without due process of law, rendering it constitutionally infirm.

PRINCIPLES:

  1. Due Process Clause - A person cannot be deprived of life, liberty, or property without due process of law. This encompasses both procedural and substantive aspects.

  2. Property Rights in Profession - The right to practice a licensed profession is considered a property right protected under the due process clause.

  3. Procedural Due Process - Notice and hearing are fundamental requirements, but are essential predominantly in quasi-judicial functions, not necessarily in executive or legislative functions.

  4. Licensure and Vested Rights - Licenses granted to professionals (including harbor pilots) to practice their profession create vested rights that cannot be arbitrarily revoked or unduly restricted without due process.

  5. Redundancy in Administrative Issuances - Enactments that duplicate existing comprehensive orders are unnecessary and may be invalidated as superfluous.