Case Digest (G.R. No. 218241) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Leovillo C. Agustin v. Hon. Romeo F. Edu, G.R. No. L-49112, decided February 2, 1979 under the 1973 Constitution, petitioner Agustin, owner of a Volkswagen Beetle equipped with factory-installed blinking lights, assailed Letters of Instruction Nos. 229 (December 2, 1974) and its amendments Nos. 479 (November 15, 1976) and 716 (June 30, 1978), which directed the mandatory installation of Reflectorized Triangular Early Warning Devices (EWDs) on all stalled, disabled, or parked motor vehicles on streets and highways. Under Letter No. 229, each owner was required to have a pair of collapsible reflectorized plates and to install them when vehicles remained stationary for thirty minutes or more; the Land Transportation Commissioner was instructed to promulgate implementing rules, which came by Administrative Order No. 1 (December 10, 1976) and Memorandum Circular No. 32 (August 29, 1978). Shortly after, President Marcos suspended the pre-registration requirement for six months and Case Digest (G.R. No. 218241) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Petitioner Leovillo C. Agustin, owner of a Volkswagen Beetle equipped with built-in blinking lights, invoked this Court’s original jurisdiction in a petition for prohibition and preliminary injunction to challenge:
- Letter of Instruction (LOI) No. 229 (Dec. 2, 1974), as amended by LOI No. 479 (Nov. 15, 1976) and LOI No. 716 (June 30, 1978); and
- Implementing rules of the Land Transportation Commission (LTC) issued by Commissioner Edu (Admin Order No. 1, Dec. 10, 1976; Memo Circular No. 32, Aug. 29, 1978).
- Petitioner alleged the LOIs and regulations:
- Violated due process and equal protection;
- Transgressed non-delegation of legislative power;
- Were arbitrary, oppressive, confiscatory and confiscatory; and
- Compelled car owners to buy costly devices despite viable alternatives.
- Regulatory Measures at Issue
- LOI No. 229 required all motor vehicles (except motorcycles and trailers) to carry one pair of triangular, collapsible reflectorized plates (15 cm base, 40 cm sides) and to place them 4 m front and rear of a stalled/disabled vehicle; directed the LTC to prepare and issue devices at cost plus 15% and promulgate rules.
- LOI No. 479 amended the procurement provision to let owners procure devices “from any source” and present them at registration; LTC to promulgate implementing rules.
- Administrative Order No. 1 (Dec. 10, 1976) detailed device specifications and serial-numbered stickers; enforcement deferred by six-month suspension (Jan. 25, 1977).
- LOI No. 716 (June 30, 1978) lifted the suspension, ordered immediate implementation; LTC Memo Circular No. 32 (Aug. 29, 1978) activated Admin Order No. 1, required free serial stickers affixed to devices, and made orders effective immediately.
- The Solicitor General, in his Answer, admitted facts, denied constitutional infirmities, cited prior jurisprudence (Calalang v. Williams; Morfe v. Mutuc; Edu v. Ericta) and the 1968 Vienna Convention ratified by P.D. 207.
Issues:
- Whether the challenged LOIs and implementing rules violate the constitutional guarantee of due process and equal protection.
- Whether the implementing rules and regulations transgress the fundamental principle of non-delegation of legislative power.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)