G.R. No. 47800 - Calalang vs. Williams

Case Summary (G.R. No. 47800)

Key Dates

July 17, 1940: National Traffic Commission adopts resolution
July 18, 1940: Chairman’s recommendation to Director of Public Works
August 2, 1940: Director’s indorsement to Secretary with modification
August 10, 1940: Secretary’s approval of closures
December 2, 1940: Decision promulgated

Factual Background

The National Traffic Commission resolved to recommend the prohibition of animal-drawn vehicles on specified sections of Rosario Street (7:30 a.m.–12:30 p.m.; 1:30 p.m.–5:30 p.m.) and Rizal Avenue (7 a.m.–11 p.m.) for one year from the opening of the Colgante Bridge. The Director of Public Works, under Commonwealth Act No. 548, forwarded the recommendation—limiting the Rizal Avenue closure to Azcárraga Street— to the Secretary of Public Works and Communications, who approved both closures. The Mayor and Chief of Police of Manila enforced the regulation, barring animal-drawn vehicles and affecting both drivers’ livelihoods and public convenience.

Applicable Law

Commonwealth Act No. 548 grants the Director of Public Works, with the Secretary’s approval, authority to:

Promulgate rules and regulations for safe transit and to prevent obstructions on national roads.
Temporarily close any or all classes of traffic on such roads when road conditions or traffic render it necessary in the public interest.
Regulate construction of structures within a reasonable distance from national roads, subject to Presidential approval.

Issue

Whether Commonwealth Act No. 548:

Constitutes an unconstitutional delegation of legislative power.
Unlawfully interferes with trade or abridges personal liberty and freedom of movement.
Violates principles of social justice by unduly favoring certain groups.

Delegation of Legislative Power

The Court affirmed that Section 1 of Commonwealth Act No. 548 does not delegate legislative power. The Act articulates the legislative policy (“to promote safe transit…and avoid obstructions”) and vests in executive officials only the discretion to ascertain and apply facts (road conditions, traffic volume, public convenience). Reliance on authorities such as Wayman v. Southard and Field v. Clark underscores that legislatures may delegate fact-finding and administrative rulemaking without ceding the power to legislate. The rules issued here implement, rather than formulate, public policy previously declared by statute.

Exercise of Police Power

The Court held that the restrictions derive from the State’s paramount police power, aimed at public safety and convenience. Commonwealth Act No. 548 was enacted to relieve traffic congestion—considered a public menace. Under established jurisprudence (U.S. v. Gomez Jesus; Dobbins v. Los Angeles; People v. Pomar), the State may impose reasonable burdens on personal liberty, property, and business when advancing general welfare. The temporary prohibition of animal-drawn vehicles on key thoroughfares fell squarely within those bounds.

Social Justice Considerat

Case Syllabus (G.R. No. 47800)

Facts of the Case

Petitioner Maximo Calalang, acting as a private citizen and taxpayer of Manila, filed a petition for a writ of prohibition.
Respondents: A. D. Williams (Chairman, 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).
On July 17, 1940, the National Traffic Commission resolved to recommend prohibition of animal-drawn vehicles on (a) Rosario Street from Plaza Calderon de la Barca to Dasmarinas Street, between 7:30 a.m.–12:30 p.m. and 1:30 p.m.–5:30 p.m., and (b) Rizal Avenue from the Antipolo Street railroad crossing to Echague Street, from 7 a.m.–11 p.m., for one year commencing with the opening of the Colgante Bridge.
July 18, 1940: Chairman Williams formally transmitted the resolution to the Director of Public Works under Commonwealth Act No. 548.
August 2, 1940: Director Fragante endorsed to the Secretary of Public Works and Communications, approving the measure with a modification—limiting the closure of Rizal Avenue to the stretch between Antipolo Street and Azcárraga Street.
August 10, 1940: Acting Secretary Bayan approved the proposed rules and regulations closing Rosario Street and the specified portion of Rizal Avenue to animal-drawn vehicles for the prescribed hours and period.
Mayor Rodriguez and Acting Chief of Police Dominguez enforced the ban, preventing all animal-drawn vehicles from passing through or picking up passengers on the affected streets.
The enforcement resulted in alleged damage to the business interests of vehicle owners and inconvenience to the riding public.

Issues Presented

Whether Commonwealth Act No. 548 constitutes an unconstitutional delegation of legislative power to the Director of Public Works and the Secretary of Public Works and Communications.
Whether the traffic rules and regulations unduly interfere with legitimate business or trade and abridge the constitutional right to personal liberty and freedom of locomotion.
Whether the regulations infringe upon the constitutional mandate for the promotion of social justice and economic security.

Statutory Provision Involved

Section 1, Commonwealth Act No. 548:
“To p