Case Summary (G.R. No. L-47817)
Creation and Powers of the MMDA
RA 7924 treats Metro Manila as a “special development and administrative region,” creating the MMDA to coordinate and supervise metro-wide services. Transport and traffic management functions under Section 3(b) include formulating and monitoring policies, standards and projects, administering enforcement operations, and instituting a single ticketing system. Section 5(e) – (f) empowers the MMDA to set traffic policies, coordinate implementation, install and administer a single ticketing system, and fix, impose, and collect fines for violations, “the provisions of RA 4136 … to the contrary notwithstanding.”
LGU Traffic Ordinances and OVR Provisions
Between 2003 and 2005, each Metro Manila LGU enacted a traffic code providing that:
- A duly deputized LGU traffic enforcer may confiscate a driver’s license upon any traffic violation;
- The “Ordinance Violation Receipt” (OVR) serves as a temporary license for five working days;
- OVRs issued by any Metro Manila LGU must be honored throughout Metro Manila.
Court of Appeals Ruling
The CA held that:
- LGUs’ OVR provisions do not conflict with RA 4136 because RA 7160 validly delegated traffic regulation to LGUs within their jurisdictions;
- RA 7924 and the LGC occupy separate domains: MMDA for metro-wide services and LGUs for local regulation; no MMDA obligation to compel LGUs to adopt a single ticketing system;
- Petitioners failed to show MMDA’s neglect in instituting a single ticketing system.
Issues on Review
- Can LGUs validly enact OVR provisions under RA 7160 despite RA 4136’s exclusive LTO mandate?
- Does RA 7924’s single ticketing mandate vest primary rule-making power in the MMDA to the exclusion of LGUs?
- Is MMDA Resolution No. 12-02 rendered ineffective by concurrent LGU OVR practices?
Supreme Court Ruling
- Actual Controversy and Justiciability
The Court found a justiciable conflict of legal rights between petitioners and respondents warranting resolution. - No Conflict with RA 4136
RA 7160’s clear grant of traffic regulation powers to LGUs does not violate RA 4136. Post-1987 constitutional delegations and successive reorganizations affirm LGUs’ authority to enact local traffic ordinances. - MMDA’s Coordinative, Not Legislative, Role
The MMDA Law entrusts the MMDA with planning, coordinating, and supervising metro-wide traffic policies and enforcement operations, including instituting a single ticketing system. It does not confer autonomous ordinance-making or police power. The MMDA’s rule-making is limited to implementing the single ticketing system and harmonizing existing rules, not to supplant LGU ordinances. - Invalidity of OVR Provisions
Because LGUs retain the power to legislate local traffic rules, the common OVR provisions in their ordinances, which arrog
Case Syllabus (G.R. No. L-47817)
Facts
- Republic Act No. 4136 (1964) created the Land Transportation Commission (later LTO) with power to apprehend, confiscate licenses, issue receipts for violations, and enforce traffic laws nationwide.
- Executive Orders 546 (1979), 1011 (1985), and 125 (1987) reorganized and renamed the land transport agency but did not expressly remove or grant license-confiscation powers.
- Republic Act No. 7160 (Local Government Code, 1991) empowered city and municipal councils to enact local ordinances regulating streets, traffic, and public conveyances within their jurisdictions.
- Republic Act No. 7924 (MMDA Law, 1995) created the MMDA to deliver metro-wide services, including traffic and transport management, with authority to set traffic policies, install a single ticketing system, and fix and collect fines, irrespective of RA 4136.
- Between 2003 and 2005, each Metro Manila LGU enacted its own traffic code authorizing deputized traffic officers to confiscate driver’s licenses and issue “Ordinance Violation Receipts” (OVRs), valid for five working days.
- On December 21, 2006, transport organizations (petitioners) filed with the Court of Appeals a Petition for Injunction and Mandamus to nullify OVR provisions and compel MMDA to implement the single ticketing system.
- While the case was pending, the MMDA adopted Resolution No. 12-02 (2012) and issued Joint Metro Traffic Circular No. 12-01 establishing a Uniform Ordinance Violation Receipt (UOVR) and a harmonized ticketing system across Metro Manila.
- On December 17, 2012, the Court of Appeals denied petitioners’ relief, upheld the LGU ordinances as constitutional, and refused mandamus for MMDA single ticketing, holding no conflict between the MMDA Law and the Local Government Code.
- Petitioners’ motion for reconsideration was denied on October 3, 2013; they then elevated the case by Petition for Review under Rule 45.
Issues
- Whether the Court of Appeals erred in declaring the LGU