Case Digest (G.R. No. 209479) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On June 20, 1964, Congress enacted Republic Act No. 4136 (the “LTO Law”), creating the Land Transportation Commission (now the Land Transportation Office, LTO) and, under Sections 29 and 62, vesting it with exclusive authority to confiscate driver’s licenses and issue prescribed receipts for traffic violations. Thereafter, the Local Government Code of 1991 (RA 7160) empowered municipalities and cities, through their Sanggunians, to “regulate traffic on all streets and bridges” and promulgate local traffic ordinances. On March 1, 1995, Republic Act No. 7924 (the “MMDA Law”) created the Metropolitan Manila Development Authority (MMDA) to coordinate “metro-wide services,” including “transport and traffic management” and the “institution of a single ticketing system,” expressly authorizing MMDA to “install and administer a single ticketing system” and “confiscate and suspend or revoke drivers’ licenses,” “the provisions of RA 4136 … to the contrary notwithstanding.” Between 2003 and Case Digest (G.R. No. 209479) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Creation and Powers of LTO
- June 20, 1964 – Republic Act No. 4136 (LTO Law) establishes the Land Transportation Commission (later LTO) and grants it, among others, the power to confiscate driver’s licenses and issue temporary receipts (§ 29) and prohibits LGUs from enacting conflicting ordinances (§ 62).
- Subsequent reorganizations by EOs 546 (1979), 1011 (1985), and 125 (1987) rename and reassign the LTO but do not expressly alter its license-confiscation power.
- LGU Traffic-Regulation Powers under the LGC
- RA 7160 (Local Government Code, 1991) §§ 447(5)(v–vi) & 458(5)(v–vi) empower municipal and city sanggunians to enact ordinances regulating traffic, streets, and public places.
- Creation and Powers of MMDA
- RA 7924 (1995) creates the MMDA to coordinate metro-wide services.
- § 3(b) includes “transport and traffic management” among metro-wide services.
- § 5(e) empowers the MMDA to set traffic policies in Metro Manila and coordinate enforcement; § 5(f) mandates a single ticketing system and authorizes the MMDA to fix, impose, and collect fines and to confiscate, suspend, or revoke driver’s licenses, “notwithstanding” RA 4136.
- LGU Traffic Codes and OVR Provisions
- From 2003–2005, the 17 cities + 1 municipality in Metro Manila enact traffic-management ordinances providing for an “Ordinance Violation Receipt” (OVR) system: deputized local enforcers confiscate licenses and issue a 5-working-day temporary driver’s license receipt, to be honored across Metro Manila.
- Proceedings Below
- Petitioners (public-utility transport operators and drivers’ associations) file for injunction and mandamus in the CA, challenging the OVR provisions as conflicting with RA 4136 and RA 7924, and seek an order directing the MMDA to implement the single ticketing system.
- CA (Dec. 7, 2012 Decision; Oct. 3, 2013 Resolution) upholds the LGU ordinances as valid, finding no conflict with the LTO Law or MMDA Law, and denies mandamus for lack of strong evidence of MMDA’s neglect.
- Petitioners elevate the case to the Supreme Court by Petition for Review on Certiorari under Rule 45.
Issues:
- Did the CA err in declaring the LGU traffic ordinances (with OVR provisions) valid?
- Did the CA err in ruling that respondent LGUs have the authority to confiscate licenses and issue OVRs?
- Is MMDA Resolution No. 12-02 (uniform ticketing system) rendered nugatory by the continued LGU OVRs?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)