Corona vs. United Harbor Pilots Association of Phil.

FACTS:
Philippine Ports Authority (PPA), pursuant to its power of control by virtue of PD 857,
issued AO-03-85 which mandates that licensed pilots which have trained and achieved
satisfactory performance are given permanent and regular appointments until they reach
the age of 70.
Later, PPA General Manager issued AO 04-92 which limited the term of appointment of
harbor pilots to one year subject to yearly renewal or cancellation after conduct of a rigid
evaluation of performance.
UHPAP requested for the suspension of the implementation of AO 04-92 arguing that due
process was not observed in the adoption of such order because no hearing was
conducted whereby relevant government agencies and the pilots themselves could
ventilate their views.
PPA countered that said AO was issued in the exercise of its administrative control and
supervision over harbor pilots under PD 857 and was intended to restore order in the
ports and to improve the quality of port services.
ISSUES:
1. Whether PPAs failure to consult pilots in the adoption of AO 04-92 amount to violation
of due process which would impair the validity of such administrative order
2. Whether the PPAs issuance of AO 04-92 tantamount to a violation of UHPAPs right to
exercise their profession
RULING:
1. NO, in the performance of its executive or legislative functions, such as issuing rules and
regulations, an administrative body need not comply with the requirements of notice and
hearing (notice and hearing, as the fundamental requirements of procedural due process, are
essential only when an administrative body exercises its quasi-judicial function)

2. YES, the renewal of their license is now dependent on a rigid evaluation of performance

which is conducted only after the license has already been cancelled. It is this preevaluation cancellation which primarily makes AO 04-92 unreasonable and
constitutionally infirm, thus, a deprivation of property without due process of law.