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MANILA, Philippines 鈥� The Supreme Court has ordered local governments in Metro Manila to stop their traffic enforcers from confiscating drivers鈥� licenses and issuing traffic violation tickets to erring motorists unless they are deputized by the (MMDA).
The local governments were instead instructed to comply with the MMDA鈥檚 single-ticketing system, which was set in place last year to harmonize traffic enforcement and penalties in the capital region.
In a decision dated July 11, 2023, but posted on the Supreme Court website only on Monday, the court en banc granted a petition for review filed by 11 transport groups against the MMDA, Land Transportation Office, 15 Metro Manila local governments and what was then the Department of Transportation and Communications.
READ: SC voids Metro Manila LGUs鈥� issuance of traffic violation tickets
Among the respondents were the municipality of Pateros and the cities of Caloocan, Las Pi帽as, Makati, Mandaluyong, Manila, Muntinlupa, Navotas, Para帽aque, Pasay, Pasig, Quezon City, San Juan, Taguig and Valenzuela.
The high court declared null and void the common provision in the traffic ordinances of these local governments that give them the power to issue ordinance violation receipts (OVRs) 鈥攖heir local traffic violation tickets鈥攖o erring motorists.
Petition to CA
The case dates back to 2006, when Fejodap, Pasang Masda, Piston, Altodap, and seven other transport groups filed before the Court of Appeals (CA) a petition for injunction and mandamus seeking to nullify the OVR provision in the local ordinances.
While the case was ongoing, the MMDA in January 2012 issued Resolution No. 12-02, adopting a uniform ticketing system.
In December 2012, the CA denied the transport groups鈥� petition for lack of merit. According to the appellate court, the local ordinances being challenged were legal and constitutional.
It said there was no conflict between Republic Act No. 7924, or the 1995 law that established the MMDA, and the Local Government Code of 1991.
Each of these laws, the CA then ruled, had its specific boundaries: the first governs the delivery of metro-wide services, while the second empowers local governments to enact ordinances.
The Local Government Code, however, only authorizes towns and cities to 鈥渞egulate traffic on all streets and bridges; prohibit encroachments or obstacles thereon and, when necessary in the interest of public welfare, authorize the removal of encroachments and illegal constructions in public places.鈥�
MMDA is 鈥榩rincipal鈥�
The Supreme Court, in its decision, said the provisions in the Metro Manila Traffic Code implied that the local ordinances remained superior regarding traffic-related matters.
This was 鈥渘ot the intention鈥� of the MMDA law, the high court said.
Based on Section 5(f) of RA 7924, the agency has the authority to administer a uniform ticketing system and 鈥渇ix, impose and collect fines and penalties for all kinds of violations of traffic rules and regulations,鈥� including the confiscation, suspension or revocation of driver鈥檚 licenses.
鈥淲hile the Court recognizes that [local governments] possess delegated legislative powers, and thus may enact regulations to promote the general welfare of the people, the fact remains that as agents of the State, it is incumbent upon them to act in conformity to the will of their principal,鈥� the Supreme Court said, noting that the MMDA law supersedes the local traffic ordinances.
In her dissenting opinion, Associate Justice Amy Lazaro-Javier said: 鈥淚t is my humble view that the MMDA is, and has always been, a mere administrative coordinating body sans any ordinance-making power. Notably, this view is strongly supported, reiterated, and espoused by a handful of landmark jurisprudence on the matter.鈥�