Case Digest (G.R. No. 47800)
Facts:
Maximo Calalang, acting as a private citizen and taxpayer of Manila, filed a petition for a writ of prohibition against several respondents, including A. D. Williams, Chairman of the National Traffic Commission, Vicente Fragante, Director of Public Works, Sergio Bayan, Acting Secretary of Public Works and Communications, Eulogio Rodriguez, Mayor of Manila, and Juan Dominguez, Acting Chief of Police of Manila. The case arose from a resolution passed by the National Traffic Commission on July 17, 1940, which recommended the prohibition of animal-drawn vehicles on specific streets in Manila during designated hours. This resolution was subsequently endorsed by the Director of Public Works and approved by the Secretary of Public Works and Communications, leading to the enforcement of these regulations by the Mayor and the Acting Chief of Police. Calalang contended that the enforcement of these regulations was detrimental to the owners of animal-drawn vehicles and the riding public...
Case Digest (G.R. No. 47800)
Facts:
Background of the Case
Maximo Calalang, a private citizen and taxpayer of Manila, filed a petition for a writ of prohibition against several respondents, including A. D. Williams (Chairman of the National Traffic Commission), Vicente Fragante (Director of Public Works), Sergio Bayan (Acting Secretary of Public Works and Communications), Eulogio Rodriguez (Mayor of Manila), and Juan Dominguez (Acting Chief of Police of Manila). The petition challenged the enforcement of certain traffic regulations.
Traffic Regulations in Question
The National Traffic Commission, in a resolution dated July 17, 1940, recommended prohibiting animal-drawn vehicles from passing along specific streets during certain hours:
- Rosario Street: From Plaza Calderon de la Barca to Dasmarinas Street, from 7:30 a.m. to 12:30 p.m. and from 1:30 p.m. to 5:30 p.m.
- Rizal Avenue: From the railroad crossing at Antipolo Street to Echague Street, from 7 a.m. to 11 p.m., for one year from the opening of the Colgante Bridge.
The recommendation was made under Commonwealth Act No. 548, which authorized the Director of Public Works, with the approval of the Secretary of Public Works and Communications, to regulate traffic on national roads.
Implementation of the Regulations
On August 10, 1940, the Secretary of Public Works and Communications approved the recommendation, and the Mayor of Manila and the Acting Chief of Police enforced the regulations. This enforcement prevented animal-drawn vehicles from operating in the specified areas, causing inconvenience to their owners and the riding public.
Petitioner’s Allegations
Calalang argued that:
- Commonwealth Act No. 548 was unconstitutional as it constituted an undue delegation of legislative power.
- The regulations interfered with legitimate business and trade and abridged the right to personal liberty and freedom of locomotion.
- The regulations infringed upon the constitutional mandate to promote social justice.
Issue:
- Whether Commonwealth Act No. 548 constitutes an undue delegation of legislative power.
- Whether the traffic regulations unlawfully interfere with legitimate business or trade and abridge personal liberty.
- Whether the regulations violate the constitutional principle of promoting social justice.
Ruling:
The Supreme Court denied the writ of prohibition, upholding the constitutionality of Commonwealth Act No. 548 and the validity of the traffic regulations. The Court ruled that:
- The Act did not delegate legislative power but merely authorized the execution of legislative policy.
- The regulations were a valid exercise of police power to promote public safety and welfare.
- The regulations did not infringe upon the constitutional mandate of social justice.
Ratio:
Delegation of Power: The Court held that the authority granted under Commonwealth Act No. 548 was not legislative but administrative. The Director of Public Works and the Secretary of Public Works and Communications were tasked with implementing the law, not making it. The distinction lies between delegating the power to make laws and delegating the authority to execute them.
Police Power: The regulations were justified under the state’s police power, which allows the government to regulate activities to protect public welfare, safety, and convenience. The Court emphasized that public welfare takes precedence over individual liberties when necessary.
Social Justice: The Court clarified that social justice does not mean favoring one group over another but ensuring the welfare of all through balanced and lawful measures. The regulations aimed to address traffic congestion, which was a public safety concern, and thus aligned with the principle of social justice.
Modern Governance: The Court acknowledged the growing complexity of modern governance, which necessitates the delegation of certain powers to administrative bodies. This delegation is not unconstitutional as long as it adheres to the principles of subordinate legislation and serves the public interest.
Conclusion:
The Supreme Court upheld the validity of the traffic regulations, emphasizing the importance of public welfare and the state’s police power. The decision reinforced the principle that individual rights may be subject to reasonable regulation in the interest of the greater good.