Anglo-Fil Trading Corp. v. Lazaro, 124 SCRA 494 (1983) Property Rights Are Subject to the Exercise of Police Power. F: The petitioners were among 23 stevedoring and arrastre operators at the Mla South Harbor. Their licenses had expired but they were allowed to continue to operate on the strength of temporary permits. On May 4, 1976, the resp Phil Ports Authority decided to allow only one org. to operate the arrastre and stevedoring services. On April 28, 1980, based on the report and recommendation of an evaluation committee, the PPA awarded the exclusive contract for stevedoring services to the Ocean Terminal Services Inc (OTSI). The petitioners brought suit in the CFI to annul the contract for exclusive service. On motion, Ct issued a TRO enjoining PPA and OTSI from implementing the exclusive contract. Later, the ct lifted the TRO prompting the petitioners to file an action for certiorari with the SC contending that: (1) ex parte lifting of TRO constituted grave abuse of discretion; (2) the award would impair the petitioners'' contracts with foreign customers. HELD: (1) Considering that the previous grant of TRO in favor of pets. was made ex parte
and w/o bond, notice and hearing of the lifting were not necessary, much less mandatory. (2) Stevedoring services are subject to regulation and control for the public good and in the interest of the general welfare.
A single contractor furnishing the stevedoring requirements of a port has in its favor the economy of scale and the maximum utilization of equipment and manpower. In return, effective supervision and control as well as collection and accounting of the govt share of revenues are rendered easier than where there are 23 contractors to oversee. As resp ct found from the evidence, the multiple contractor system has bred cut-throat competitions in the port . Understandably, most contractors had been unable to acquire sufficient modern facilities , observe labor standards, maintain efficiency, and pay PPA dues. The contention of pets. that due process was violated resulting in a confiscation of private property is likewise without merit. In the first place, the pets were operating merely on "hold over"permits. In the second place, the award of OTSI was the result of a evaluation of performance of existing contractors made by a special committee created by the PPA