THE SOLICITOR GENERAL, RODOLFO A. MALAPIRA, STEPHEN A. MONSANTO, DAN R. CALDERON, and GRANDY N. TRIESTE vs. THE METROPOLITAN MANILA AUTHORITY and the MUNICIPALITY OF MANDALUYONG .
- G.R. Number: G.R. No. 102782
- Promulgated: 1991-12-11
- Ponente: Cruz, J.
Doctrine
Confiscation of motor-vehicle license plates for traffic violations is not authorized under PD 1605 and driver-license confiscation likewise lacks statutory authority; LOI 43 remains the exception for stalled vehicles obstructing streets.
Delegated regulatory authority must be bounded by a sufficient standard to map out the delegate's powers; 'convenience and welfare' of the public is an acceptable sufficient standard in this context.
It is for Congress, in its discretion, to authorize such sanctions directly by statute or by delegating the authority to local governments; absent such action PD 1605 continues to prohibit these confiscatory penalties.
Facts
A prior ruling, the Court held confiscation of license plates for traffic violations was not authorized under PD 1605 and driver-license confiscation was likewise not prescribed by the decree (citing decision discussed in the petition).
The Solicitor General filed a motion to resolve a petition for prohibition seeking to enjoin enforcement of Metropolitan Manila Authority Ordinance No. 11, Series of 1991 and Municipality of Mandaluyong Ordinance No. 7, Series of 1988; the petition is docketed as G.R. No. 102782.
Several related cases were consolidated or considered together because they presented the same fundamental question, and procedural objections were passed over as presenting no practical benefit to decide.
The Court recognized the ordinances were enacted to curb traffic and shared the public's concern over traffic reduction, but noted statutory prohibition against the sanction and public misgivings over enforcement abuses shown in Gonong.
Issues
Whether Ordinance No. 11, Series of 1991 of the Metropolitan Manila Authority and Ordinance No. 7, Series of 1988 of the Municipality of Mandaluyong may validly authorize removal of motor-vehicle license plates and confiscation of driver's licenses for traffic violations.
Ruling
The Court declared both ordinances NULL and VOID and enjoined all law-enforcement authorities in Metropolitan Manila from removing license plates (except as authorized under LOI 43) and from confiscating driver licenses for traffic violations; the Court affirmed its prior ruling.
Keywords
G.R. No. 102782, Metropolitan Traffic Command, West Traffic District vs. Hon. Arsenio M. Gonong, G.R. No. 91023, confiscation of license plates, confiscation of driver's licenses, traffic violations, PD 1605, LOI 43, Ordinance No. 7, Series of 1988 Mandaluyong, Ordinance No. 11, Series of 1991 Metropolitan Manila Authority, EO 392, delegated legislative power, collateral attack, direct action, actual case or controversy, violation of law, driver, confiscation, license plates, licenses, ordinance