Case Digest (G.R. No. 47800) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Maximo Calalang, Petitioner, acting as a private citizen and taxpayer of Manila, filed an original petition for a writ of prohibition on December 2, 1940, against 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 the City of Manila, and Juan Dominguez, Acting Chief of Police of Manila. Calalang challenged the enforcement of a resolution by the National Traffic Commission dated July 17, 1940, which recommended barring animal-drawn vehicles from traversing Rosario Street (Plaza Calderon de la Barca to Dasmarinas Street) during morning and afternoon peak hours, and Rizal Avenue (railroad crossing at Antipolo Street to Echague Street) from 7 a.m. to 11 p.m., for one year starting with the opening of the Colgante Bridge. On July 18, 1940, the Commission’s Chairman formally proposed the measure to the Director of Public Works under Co Case Digest (G.R. No. 47800) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Petition
- Maximo Calalang, private citizen and taxpayer of Manila, petitions for a writ of prohibition.
- Respondents:
- 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.
- Juan Dominguez, Acting Chief of Police of Manila.
- Administrative Proceedings
- July 17, 1940: National Traffic Commission resolution recommends prohibiting animal-drawn vehicles on:
- Rosario Street (Plaza Calderon de la Barca to Dasmarinas Street) from 7:30 a.m. to 12:30 p.m. and 1:30 p.m. to 5:30 p.m.
- Rizal Avenue (railroad crossing at Antipolo Street to Echague Street) from 7 a.m. to 11 p.m., for one year from opening of the Colgante Bridge.
- July 18, 1940: Chairman Williams recommends the same to Director of Public Works under Commonwealth Act No. 548.
- August 2, 1940: Director Fragante’s first indorsement modifies Rizal Avenue limit to Antipolo Street–Azcárraga Street.
- August 10, 1940: Secretary Bayan approves the modified recommendation for one-year closure.
- Enforcement and Effects
- Mayor Rodriguez and Chief of Police Dominguez enforce the regulations.
- Animal-drawn vehicles barred from passing or picking up passengers in the designated zones, allegedly harming vehicle owners and restricting public convenience.
Issues:
- Whether Commonwealth Act No. 548 constitutes an undue delegation of legislative power.
- Whether the traffic regulations unlawfully interfere with legitimate business or trade.
- Whether the regulations abridge personal liberty and freedom of locomotion.
- Whether the regulations infringe the constitutional mandate to promote social justice and economic security.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)