Law School Noob: [CASE DIGEST] CORONA v. UNITED HARBOR PILOTS ASSOCIATION OF THE PHILIPPINES (G.R. No. 111953)

Wednesday, June 24, 2020

[CASE DIGEST] CORONA v. UNITED HARBOR PILOTS ASSOCIATION OF THE PHILIPPINES (G.R. No. 111953)

October 12, 1998

Ponente: Per Curiam

Plaintiff-Appellee: People of the Philippines
Accused-Appellant: Benedicto Ramos

FACTS

On July 15, 1992, Phil. Ports Authority General Manager Rogelio Dayan issued PPA-AO No. 04-92, which put a one-year cap on all appointments to all harbor pilot positions in all pilotage districts. This meant that all pilots shall be subject to an annual performance review to determine whether or not their employment will be renewed.

On August 31, 1992, the PPA issued Memorandum Order No. 08-92, which specified the criteria to be used in the annual performance reviews.

Prior to the issuance of the AO and MO, all duly licensed pilots had security of tenure until they reach the mandatory age of retirement (70), unless at any point they have been found to be physically or mentally unfit.

UHPAP and MPA assailed the validity of these issuances. In their complaint before the DOTC, they were told the matter was within the jurisdiction of PPA and not DOTC.

Herein respondents filed a complaint before the Office of the President. Corona held the implementation of the issuances in abbeyance pending review, but he subsequently lifted such an abbeyance and held that these were valid on the ground that PPA is mandated to "control, regulate and supervise pilotage and conduct of pilots in any port district."

Herein respondents filed before the RTC of Manila a petition for certiorari, prohibition, and injunction with prayer for the issuance of a TRO. RTC ruled in favor of UHPAP and MPA, hence this petition by herein petitioners.

ISSUE

Whether or not respondents were denied due process.—YES.

RULING

In order for an act to qualify as a deprivation of another party's right to due process, two conditions must concur: (a) there is a deprivation, and (b) such deprivation is carried out without proper observance of due process. Both of these conditions are present in this case.
On due process: The Court noted that PPA followed procedural due process in the sense that herein respondents were given the opportunity to file a complaint and be heard at the DOTC, OP, RTC, and now the SC.
However, PPA failed to observe substantive due process by impinging on a vested right, which in this case is the sole and exclusive right of herein respondents to the exercise of harbor pilotage.
Pilotage as a profession has taken on the nature of a property right.
Before anyone can assume employment as a harbor pilot, he has to undergo 5 different exams and years of OJT. Only after the completion of these requirements shall he be issued a license, which allows him to engage in pilotage until the age of 70.
It is readily apparent that the assailed AO unduly restricts the right of harbor pilots to enjoy their profession before their compulsory retirement.
The pre-evaluation cancellation policy espoused by the AO is unreasonable, constitutionally infirm, and a deprivation of property without due process of law.

NOTE

Difference between procedural and substantive due process: the former refers to the "method or manner by which the law is enforced," while the latter "requires that the law itself, not merely the procedures by which the law would be enforced, is fair, reasonable, and just."

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