Case Digest (G.R. No. 130230) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Metropolitan Manila Development Authority vs. Dante O. Garin (G.R. No. 130230, April 15, 2005), the respondent, Dante O. Garin, was apprehended on August 5, 1995 for illegal parking along Gandara Street, Binondo, Manila. The MMDA traffic enforcer issued him a Traffic Violation Receipt (TVR) under Section 5(f) of Republic Act No. 7924 and confiscated his driver’s license, valid as a temporary permit for seven days. Garin wrote to then-MMDA Chairman Prospero Oreta requesting his license’s return and expressing his wish for judicial proceedings. Receiving no response, he filed a complaint with a preliminary injunction in RTC-Parañaque on September 12, 1995, arguing that without implementing rules, Section 5(f) vests the MMDA with unbridled discretion—violating the due process and bar on undue delegation of legislative power. The MMDA cited its limited executive and legislative nature, the existence of administrative remedies, and an April 15, 1995 Memorandum Circular No. TT-95-0 Case Digest (G.R. No. 130230) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Incident and Traffic Violation Receipt (TVR)
- On 05 August 1995, respondent Dante O. Garin parked illegally along Gandara Street, Binondo, Manila; apprehended by MMDA enforcers.
- MMDA issued a TVR and confiscated his driver’s license, stating:
- Report to MMDA Traffic Operations Center after 48 hours.
- Criminal case if license not redeemed in 30 days.
- TVR valid as temporary license for seven days.
- Administrative and Judicial Proceedings
- Garin wrote MMDA Chairman Prospero Oreta for return of license and requested court filing; received no reply.
- On 12 September 1995, Garin filed a complaint with preliminary injunction in RTC Parañaque, challenging:
- Section 5(f) of RA 7924 for granting MMDA unbridled discretion to confiscate licenses without judicial review, violating due process.
- Undue delegation of legislative power to MMDA to impose unspecified fines and penalties.
- MMDA, via the Solicitor General, argued:
- Powers under Sec. 5(f) are administrative; judiciary retains right to determine penalty validity.
- MMDA Memorandum Circular No. TT-95-001 (15 April 1995) implemented Sec. 5(f).
- Garin contested the circular’s validity for lack of quorum; RTC granted:
- TRO extending TVR validity (26 September 1995).
- Preliminary mandatory injunction ordering return of his license (23 October 1995).
- On 14 August 1997, RTC rendered judgment:
- Held circular void ab initio for lack of quorum.
- Confiscation without hearing violates due process.
- Made injunction permanent; barred MMDA from future summary confiscations.
- MMDA petitioned to the Supreme Court, arguing:
- License is a revocable privilege, not property.
- Licensee may appeal via payment, MMDA Adjudication Committee protest, or referral to the Prosecutor’s Office.
- Circular 04-2004 (12 August 2004) established the Metropolitan Traffic Ticket scheme, rendering the case moot but meriting guidance for future enforcement.
Issues:
- Whether Section 5(f) of Republic Act No. 7924 unconstitutionally delegates legislative or police power to the MMDA to confiscate, suspend, or revoke driver’s licenses.
- Whether MMDA Memorandum Circular No. TT-95-001 is valid or void for want of a quorum.
- Whether summary confiscation under Sec. 5(f) violates the constitutional due process guarantee.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)