"Far from extinguishing the controversy, the Order deepens and institutionalizes the assailed consolidation requirement," PISTON said in its pleading.
The legal challenge centers on the constitutionality of forced franchise consolidation. The group claims the mandate violates drivers' and operators' freedom of association, as well as their rights to livelihood, due process and equal protection.
Under the policy, small operators and drivers must join cooperatives or corporations to continue operating public utility vehicles.
PISTON argued that even if the Supreme Court considers the case technically moot, it should issue a definitive ruling because the issue is "capable of repetition yet evading reviewẠạị
The group cited that the government has repeatedly modified, reopened or extended consolidation deadlines through various department orders, board resolutions and memorandum circulars.