Tuesday, April 29, 2025

Domestic shipping lines ask Dizon to abrogate centralized ticketing system AO

Domestic shipping lines are strongly urging Transportation Secretary Vivencio B. Dizon to annul Administrative Order No. 12-2019, or the centralized ticketing system (CTS), and remove it from the Electronic Terminal Management System (ETMS). They warn that its implementation will only create inefficiencies in port operations and impose additional financial burdens not only on shipping operators but also on passengers and the entire Philippine economy.

In a letter submitted to Dizon on April 11, 2025, the Philippine Inter-Island Shipping Association (PISA) requested the “abrogation, annulment, or otherwise recall of PPA Administrative Order No. 12-2019 entitled ‘Policy on the Centralized Ticketing System (CTS) Relative to an Online Application Integrating the Booking and Payment Processes for the Use of Ship and Passenger Terminal in a Single Platform’ and consequently the removal of the CTS from the ETMS.” The said AO was issued by the Philippine Ports Authority (PPA) on November 18, 2019, but was put on hold by the previous two DOTr secretaries: Arthur Tugade and Jaime Bautista.

According to the group, AO No. 12-2019 is “without legal basis, unconstitutional, and detrimental to the shipping industry, passengers, and the economy as a whole. It is an unnecessary and intrusive measure that disregards existing private-sector solutions, disrupts business operations, and raises serious concerns about government overreach, data privacy, and economic inefficiencies.”

Foremost, the group alleged that the contract for the P499.898 million ETMS with the joint venture of NextIX and Carus Ferry Ab Ltd. was signed by the PPA on February 9, 2022, despite ongoing objections from various stakeholders. The contract covers the supply, delivery, installation, and commissioning of the ETMS, including cloud-based unified electronic ticketing capabilities.

PISA stressed that the use of public funds will ultimately be shouldered by taxpayers and passengers. Instead, the group recommended that the PPA focus on improving port infrastructure, which is its core responsibility under the law.

No Authority

Secondly, PISA contended that the PPA has no authority to issue the questioned administrative order that requires a centralized ticketing system for domestic RoRo/passenger ships calling at ports under the jurisdiction of the PPA and for their riding passengers.

PISA noted that PPA’s authority is strictly limited to port operations and logistics, such as berthing, mooring, towing, docking, cargo handling, and warehousing. “There is no mention of ticketing, fare collection, or any authority over the financial transactions between shipping operators and passengers,” it added.

While Section 26 of PD No. 857 grants the PPA the power to regulate port operations, PISA insisted this does not extend to the commercial decisions of shipping lines, including how they manage ticketing and payment collection. “Certainly, the booking and fare collection process is a fundamental aspect of business operations that falls within the management prerogative and discretion of shipping companies. The PPA, therefore, has no authority to interfere in these private commercial transactions, especially in the absence of any legal mandate,” the letter added.

Redundancy

In addition, most shipping companies have functioning online ticketing systems that efficiently manage bookings, payments, and passenger data.

By centralizing ticketing under the government’s control, PISA argued that the PPA would severely disrupt an already functioning system and force companies to abandon their investments in their own booking platforms, resulting in additional costs, inefficiencies, and business uncertainty. Implementation of the CTS would compel shipping companies to abandon their existing ticketing contracts, violating their right to private enterprise and freedom to contract.

PISA cited the Supreme Court ruling in Goldenway Merchandising Corporation vs. Equitable PCI Bank (GR No. 195540, March 13, 2013) that stated contracts should not be altered or impaired by subsequent laws, much less an administrative order. Consequently, AO 12-2019 directly violates this principle, rendering it legally unsound and unconstitutional.

Moreover, if a shipping company’s vessel calls at a port not under the PPA, that company would have to maintain two online ticketing systems, adding undue burdens to doing business in the Philippines.

Interference

The implementation of the CTS, PISA warned, will create unprecedented and unwarranted government interference in private business.

The shipping industry, which provides the most economical and efficient means of connecting the various islands of the country, should not be subjected to unnecessary burdens not imposed on other modes of public transport, PISA. It noted that if land and air transportation—which also serves millions of passengers—operate without a government-mandated centralized booking system, there is no reason why a centralized ticketing system should be imposed on the shipping industry. “Requiring shipping companies to join the central ticketing system is a step in the wrong direction,” the PISA letter added.

PISA further noted that developed countries like the United States, Japan, South Korea, and Germany, among others, recognize and respect the autonomy of the private sector and businesses in managing their operations, including ticketing systems, as they do not intervene in the ticketing processes of private shipping companies.

“A CTS is a dangerous setup,” PISA stated, because a government-controlled, centralized ticketing system creates a single point of failure. If the CTS crashes due to technical issues, cyberattacks, or mismanagement, the entire shipping industry will come to a standstill, leading to the paralysis of national shipping operations.

The group also raises the issue of data privacy, stating that AO No. 12-2019 fails to provide any concrete measures on how personal and sensitive passenger information will be processed, stored, and protected.

Other government agencies — Anti Red Tape Authority, Maritime Industry Authority, Department of Trade and Industry, and the PPA — were also furnished with the same PISA letter.

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