Title
Calalang vs. Williams
Case
G.R. No. 47800
Decision Date
Dec 2, 1940
A taxpayer challenged traffic regulations restricting animal-drawn vehicles in Manila, alleging unconstitutional delegation of power and infringement on liberty. The Supreme Court upheld the regulations, ruling they were a valid exercise of police power for public welfare.

Case Summary (G.R. No. 47800)

Factual Background and Administrative Chronology

The National Traffic Commission adopted a resolution (July 17, 1940) recommending prohibition of animal-drawn vehicles on specified portions of Rosario Street and Rizal Avenue during designated hours for one year commencing with the opening of the Colgante Bridge. The Chairman of the National Traffic Commission forwarded the recommendation to the Director of Public Works (July 18, 1940). The Director of Public Works, in an indorsement (August 2, 1940), recommended approval with a modification narrowing the closed portion of Rizal Avenue. The Secretary of Public Works and Communications, by a subsequent indorsement (August 10, 1940), approved closing Rosario Street and (the modified) portion of Rizal Avenue to animal-drawn vehicles during the indicated hours for the one-year period. The Mayor and Acting Chief of Police of Manila enforced the rules, resulting in denial of passage and passenger pickup by animal-drawn vehicles in the specified areas, which prompted the petition.

Procedural Posture and Relief Requested

Calalang filed for a writ of prohibition in the Supreme Court to restrain respondents from enforcing the administrative rules and regulations adopted pursuant to Commonwealth Act No. 548. The petition challenged constitutional validity and sought to prevent enforcement by executive and local officials. The Court resolved the matter on the merits and denied the writ.

Legal Issue — Alleged Undue Delegation of Legislative Power

The petitioner argued Commonwealth Act No. 548 was unconstitutional as an undue delegation of legislative power because it authorized the Director of Public Works, with the Secretary’s approval, to promulgate rules regulating use and traffic on national roads, and to temporarily close such roads. The Court analyzed Section 1 of Commonwealth Act No. 548, which authorizes the Director, with Secretary approval, to promulgate necessary rules and regulations to regulate and control use and traffic on designated national roads; to include provisions controlling construction within a reasonable distance along national roads with Presidential approval; and to temporarily close roads to any or all classes of traffic when road condition or traffic makes such action necessary or advisable in the public convenience and interest, or for a specified period, with Secretary approval.

Court’s Analysis on Delegation Doctrine and Administrative Discretion

The Court rejected the delegation challenge. It reiterated the classical distinction between a prohibited delegation of the power to make law and a permissible delegation of authority to execute and implement legislative policy by determining facts and conditions that trigger legislative directives. The Court relied on prior Philippine and foreign authority (including Rubi v. Provincial Board of Mindoro and cited U.S. precedents) to support the proposition that the Legislature may prescribe a policy and entrust subordinate officials with the administrative discretion to apply that policy to particular facts and circumstances. The Court held that Commonwealth Act No. 548 does not transfer legislative power to make law; rather it establishes legislative policy — to promote safe transit and avoid obstructions on national roads — and confers on the Director and Secretary the administrative authority to promulgate rules and ascertain when road conditions or traffic render temporary closure necessary or advisable. The power delegated is thus one of execution and fact-finding, not of making substantive law.

Court’s Characterization of the Administrative Function

The Court described the acts of promulgating traffic rules and determining when a national road should be temporarily closed as administrative functions that logically require on-the-spot judgment by an executive official. It emphasized the necessity of vesting discretion in administrative authorities to enable responsive governance in situations where conditions evolve or are not fully knowable at the time of legislative enactment. Quoting authorities that distinguish permissible delegation (to determine facts or conditions on which legislative policy depends) from impermissible delegation (to make the law itself), the Court found the statutory scheme constitutionally acceptable.

Legal Issue — Police Power, Liberty, and Interference with Business

Calalang contended the regulations unlawfully interfered with legitimate business, abridged personal liberty, and impaired freedom of locomotion. The Court framed Commonwealth Act No. 548 as an exercise of the State’s police power aimed at promoting safe transit and avoiding obstructions on national roads, enacted in the interest of public convenience and welfare. The Court explained that exercise of the police power can legitimately impose restraints on personal liberty, property, and business occupations when necessary to secure the general comfort, health, safety, and prosperity of the community. The Court observed that lawful businesses may be regulated or even curtailed when changing conditions make them a menace to public welfare, and cited precedents recognizing the continuing and adaptable nature of police power in response to advancing civilization and changing social needs.

Court’s Rationale on Proportionality and Public Welfare

Although the Court did not undertake a formal proportionality analysis as framed in modern constitutional jurisprudence, it implicitly endorsed the legislative choice to prioritize public safety and traffic management over the unrestricted operation of animal-drawn vehicles in con

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