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^22
PDGen,EDGARB.AGLI PNP(ret.) DeCember 5, 2477
Chairman Emeritus
RUPERTO S. BAYOCOT
Chairman
MARIO O. YAP
HOI{. MARK A. VILLAR
Pre nt
EDITHAA. MACASI
Secretary
vice-presidentrar tnternatAffatrs Depaftment of Public Works and Highways (DPWH)
MARIAB. ZA DPWH Head Office, Bonifacio Drive,
JAY ION D. ERCIA
Fort Area, Manila
gurcT
JESUSITO Y. CORTEZ Dear Secretany Villar,
Aut
CARLITO M, VIL UEVA
rate Secretary Greetings from the Confederation of Truckers Association of the
EDUARDOCAR K, DAVID Philippines, Inc. (CTAP)!
Asst Secrctary
VIRGILIO M. ERO
PR.O, In connection with the impending expiration on the implementation
of overloading under Code 12-2 and 12-3, CTAP have the honor to
COL, R0D0LF0 T. DE OCAMPO (ret.) forward/submit to your good office, herein attached Position Paper in
GABRIEL L. CRUZ
reference on the above mentioned subject matter.
AMBROCIO N. DAMIAN JR.
PEPITO P. DINO
NILOA. MANIKAN Fr:rther, CTAP would like to seek an audience with you to discuss the
RONALD C. QUINTINIO
details of our concerns on this matter.
ALBERTO H. SUANSING

Cagayan Aggregates and River Gravel

Haulers Associatron lnc. (CARGHA)
Leyte Truckers lssociation (LH
Negros Consolidated Tn:ckers
Association (CON
Truckers Association of Davao to
Accelerate Development (TADTAD)
Thank you for the opportunity of correspondence as we assure of our
continued good will and cooperation.
)
Hoping for your favorable and imrnediate action on this matter.
)

RAMONV.MA N
1985-1990
ALBERTO H. SUANSING
1 990-1 992 YAP
TEOOORO R, MALONZO
1992-1994
JOSE Y. CORTEZ
199+2002
COL. RODOLFO T. DE OGAMPO (ret.)
2M2-2408
RUPERTOS. OCOT
2009-2015
EDGARDO Y. OTEGO
201F2016
November L6, 2017

HON. MARK A. VILLAR

Secretary
Depaftment of Public Works and Highways (
DPWH Head Office, Bonifacio Drive,
Port Area, Manila EI
.:.-r E}
.a-.F

6 2017

CTAP POSITION PAPER

(RE: Implementation of Republic Act No. 8794 on code l2-2 and t2-3
otherwise known as'*An Act Imposing a Motor Vehicle User's Charge on Owners
of all Types of Motor Vehicle and for other Purposes')

The Confederation of Truckers Association of the Philippines, Inc. (CTAP) is a

registered national organization of various local associations of trucking
operators all over the country, and member of the ASEAN Trucking Federation
(ATF) primarily established to protect and uphold the legitimate concerns and
interest of the Philippine Trucking Industry, with the following member
organizations:
1. Philippine Pofts and Transpott Council Inc. (PPTC)
2. Manila North Harbor Truckers Association Inc. (MNHTA)
3. Manila Seair Truckerc Association (MASTA)
4. Aduanas Business Club Inc. (ABCI)
5. Truckers Association for Philippine Economic Zone (TRAPEZ)
6. Truck Operators Association of the Philippines, Inc, (TAP)
7. Haulers for International Liners Association (HIU)
B. Montalban - San Mateo Truckers Association, Inc. (MSMTAI)
9. Food Haulers Association of the Philippines (FHAP)
10. Cebu Truckers Association Inc. (CTAI)
11. United Hauler and Arms Association of the Phils., Inc. (U-HAAPI)
12. Federation of Waterfront Truck Operators of the Philippines, Inc.
(FEWTOP)

@
 13. Philippine Integrated Haulers and Truckers Organization (PIHTO)
14. Subic Integrated Truckers Association - Philippines, Inc. (SITAP)
15. Integrated Truckers Association of the Philippines (INTAPHIL)
As a rule, CTAP supports and extends assistance to all its member associations
and their member trucking operators in whatever capacity the confederation can
offer that accounts for 9,100 truck units as per CTAP available record.

Verily, CTAP supports and in unity with the DPWH in its salutary endeavor of
elevating and modernizing the standard of trucking seruices in our country.
Besides, in this era of free market and globalization along with the advent of
Asian Integration, it is actually to our advantage that the quality and standard
of trucking seruice shall take off initially to a higher notch for us to be
competitive with our neighboring countries.
We write in reference to the impending expiration of the moratorium granted
by your good office with regards to the implementation and enforcement of the
maximum allowable gross vehicle weight (GVW) for trailer trucks under codes
72-2 and 12-3 under Republic Act No. 8794 which would expire this December
3L,20L7.

CTAP duly acknowledge the noble intentions of Republic Act No. 8794 of
preserving our countryt roads and bridges from further damage and
deterioration brought by overloaded vehicles. However, much to our desire to
comply to the specifications under the said law, majority of our members is not
financially ready to purchase new trailer units as mandated under Republic Act
No. 8794 due to the economic slowdown and spiraling cost of trucking
operations.

In relation to the specifications mandated as per provisions of Republic Act No,

8794 othenruise known as 'Anict imposinq a Motor Vehicle User's Charge on
Ownerc of all Types of Motor Vehicle and for other Purposes", CTAP hereby
submits the following comments and elucidation:

1. Presently, under the Amended Rules and Regulations (IRR) on

overloading as mentioned in Republic Act No. 8794, othemrise known as
'tAn Act Imposing a Motor Vehicle User's Charge on Owners of all Types
and for other Purposes", Code l2-2 categorizes semi-
"
WVehicle
 trailer trucks with three (3) axles at motor vehicle and two (2) axles at
trailer (18 wheels) to have a MGVW of up to 41,500 kg. Code 12-3
identifies semi-trailer with three (3) axles at motor vehicle and three (3)
axles at trailer (22 wheels) to have a MGVW of up to 42,000 kg. only

However, the MGVW for L2-2 and 12-3 set by DPWH failed to considered
that the average weight of containers arriving in the Philippines is around
30,000 to 36,000 kg. If we add the minimum weight to that the tare
weight of the tractor head and trailer itself which is at an average of
around 15,000 kg., we would get a total weight of 43,500 kg., which is
an automatic violation of the law. So even if all truckers and other
stakeholders in the industry acquired equipment in compliance with the
DPWH Resolution but the MGVW under Code L2-2 and 12-3 remains the
same, the problem of overloading will still persist.

2. To date, no mandatory weighing of container cargo was conducted within

the post premises prior to its eventual exit in order that overloaded
container cargo that exceeds the maximum weight shall not be permitted
to exit the port premises in order to protect our government roads and
bridges. Thus, there is an imperative necessity that a mandatory weighing
must be conducted with the poft premises and the result thereof must be
honored/recognized to avoid confusion in the implementation of Reoublic
Act No. 8794
of GW under codes t2-2 and I2-3.

3. CTAP hereby proposed to consider amending further the MGVW under

I2-2 from 41,500 to 53,500 kg. and 12-3 from 42,0AA to 54,000 kg. but
was turned down. The increases mentioned would have been the same
weight if the basis of apprehension would still be the 13.5 tons per axle
on Code t2-2 and t2-3. We hope that the mentioned MGVW would be
most reasonable and will enable truckers to comply with R.A. 8794. There
would not be any more need to issue a Public Advisory on Anti-
Overloading every 6-month suspending the GVW on trucks / trailers under
Code l2-2 and L2-3.

4. In realigr though,
we would need a truck and trailer with a tare weight of
10,000 kg. to 11,500 kg., which would be impossible since the
 average tare weight of such is 15,000 kg. for Code l2-2 and 16,000 kg.
for Code L2-3. Going back to our earlier point, the average weight of
containers coming into the country is at 30 to 36 MT, possibly more
especially with reefer containers, added to the average tare weights
mentioned, the trucker would automatically constitute a violation.
Overloaded trucks are fined with 25olo of the amount of their motor vehicle
user's charge (MVUC) applicable to the vehicle at the time of infringement.

5. Ironically, if the maximum allowable gross vehicle weight (GVW) under

Codes L2-2 and 12-3 be implemented, then eighty percent (80o/o) of the
container of the container cargoes stockpiled at the Poft of Manila could
no longer be transported which would put to naught the effoft of the
government to facilitate a seamless and sustainable mobility of container
cargoes at the Poft of Manila.

Thus, CTAP take this opportunity to reiterate that the concerned government
agencies review its policies on overloading, pafticularly on the basis of
overloading and meet with industry proponents so that a solution viable to all
would be reached. If no agreement will be reached, this will only lead to future
issuance of Public Advisories suspending implementation and possibly, future
protests from disgruntled transport groups, disrupting economic movement.

oveiloaded caroo oubide the port oremises,

For the consideration of the Honorable Secretary of the Depaftment of Public

Work and Highways.

Thank you and anticipating your favorable and immediate action on this matter.
With utmost support for your leadership, we remain.

,frspectfully submitted.
9.
 City of Manila, 16th November

.Y, PNP (ret.)

-meritus

ALBERTO H. SUANSING
President - MASTA

ILIO M. JAMERO ALD C. QUTNTTNTO

President - MSMTAI

coL. PO (ret.)