Case Summary (G.R. No. 130230)
Key Dates
– 05 August 1995: Respondent’s license confiscated; Traffic Violation Receipt (TVR) issued
– 12 September 1995: Complaint with application for preliminary injunction filed in RTC Parañaque
– 26 September 1995: RTC issues temporary restraining order extending TVR’s validity
– 23 October 1995: RTC grants preliminary mandatory injunction ordering return of license
– 14 August 1997: RTC renders decision permanently enjoining MMDA from license confiscation without hearing
– 15 April 2005: Supreme Court decision on petition for certiorari
Applicable Law
– 1987 Philippine Constitution: Due process, separation of powers, non-delegation doctrine
– Republic Act No. 7924 (1995): Creation of MMDA; Section 5(f) authorizing fine imposition and license confiscation, suspension, revocation
– Republic Act No. 4136 (Land Transportation and Traffic Rules, 1964)
– Presidential Decree No. 1605 (Granting Metro Manila Commission traffic management powers, 1978)
Procedural History
- MMDA traffic enforcers issue TVR and seize Garin’s driver’s license for illegal parking.
- Garin writes the MMDA Chairman seeking release of his license and a court hearing; no response.
- He files suit in RTC Parañaque alleging Section 5(f) grants MMDA unbridled discretion, violates due process and unlawfully delegates legislative power.
- RTC issues TRO, then a preliminary mandatory injunction, and finally a decision in August 1997 declaring MMDA Memorandum Circular TT-95-001 void for lack of quorum and enjoining summary license confiscation.
- MMDA appeals by petitioning the Supreme Court for certiorari.
Issues Presented
- Whether Section 5(f) of RA 7924 validly authorizes MMDA to confiscate and suspend or revoke driver’s licenses without prior hearing, consistent with due process.
- Whether the grant of authority to fix and impose unspecified fines constitutes an undue delegation of legislative power.
- Whether MMDA possesses inherent police power to enforce traffic laws or merely administrative authority.
RTC Ruling
– Memorandum Circular TT-95-001 was void ab initio for lack of a quorum in the Metro Manila Council meeting that purportedly approved it.
– Summary confiscation and continued holding of a license without a hearing deprived Garin of property without due process.
– Permanent injunction issued: MMDA must return the license and refrain from confiscation without affording the driver an opportunity to be heard.
Arguments on Appeal
Petitioner MMDA contends:
– A driver’s license is a privilege, not property; suspension or revocation under police power does not implicate “taking” without due process if appeal mechanisms exist.
– Licensees may (a) pay the fine voluntarily, (b) submit a protest to the MMDA Adjudication Committee, or (c) refer the TVR to the Public Prosecutor’s Office.
– RA 7924 is self-executory; no further implementing rules are needed for Section 5(f).
– MMDA Memorandum Circular TT-95-001 was validly adopted with a quorum; RTC’s finding was a misapprehension of fact.
Mootness and Academic Nature
– In August 2004, MMDA Circular No. 04-2004 introduced the Metropolitan Traffic Ticket (MTT) system, eliminating routine license confiscation and allowing fine payment within seven days.
– The new scheme renders the controversy over TT-95-001 and summary confiscation moot, but the Court proceeds to clarify MMDA’s authority for future reference.
Legal Analysis – Nature of a Driver’s License
– Consistent with 1987 Constitution jurisprudence, a driver’s license is a state-granted privilege exercisable under the police power to ensure public safety and welfare.
– Courts have recognized similar privileges in licensing cockpits, timber operations, and electric franchises, all subject to revocation for noncompliance with conditions.
Legal Analysis – MMDA’s Powers and Police Power
– MMDA is an administrative “development authority” created by Congress in RA 7924; it is not a local government unit vested with legislative power or inherent police power.
– In Metro Manila Development Authority v. Bel-Air Village Association, Inc., the Court held that MMDA exercises only administrative, coordinative, regulatory, and supervisory functions but lacks ordinance-making or inherent police power.
– Police power remains primarily with the National Legislature and may be delegated to LGUs under the Local Government Code of 1991, which does not include the MMDA.
Statutory Interpretation – Section 5(f) of RA 7924
– Section 5(f) imposes a duty on t
Case Syllabus (G.R. No. 130230)
Facts of the Case
- On August 5, 1995, Dante O. Garin was issued a Traffic Violation Receipt (TVR) and had his driver’s license confiscated for illegal parking on Gandara Street, Binondo, Manila.
- The TVR instructed Garin to report to the MMDA Traffic Operations Center after 48 hours, warned that a criminal case would be filed if he failed to redeem his license within 30 days, and served as a temporary license for seven days.
- Garin wrote to MMDA Chairman Prospero Oreta requesting immediate return of his license and expressing his desire for judicial resolution; he received no response.
Procedural History
- On September 12, 1995, Garin filed a complaint with an application for preliminary injunction before RTC Parañaque, Branch 260.
- He alleged Section 5(f) of Republic Act No. 7924 granted MMDA unchecked discretion to confiscate licenses without due process, and that absence of implementing rules rendered the TVR void.
- Garin claimed irreparable harm from license deprivation.
- The MMDA, through the Solicitor General, defended its authority to fix, impose, and collect fines as legislative and executive in nature, with the judiciary retaining power to review penalties.
- MMDA pointed to Memorandum Circular No. TT-95-001 (April 15, 1995) as its implementing regulation; Garin challenged its validity for lack of quorum in the Metro Manila Council.
- On September 26, 1995, the RTC issued a temporary restraining order extending TVR validity; on October 23, 1995, it granted a preliminary mandatory injunction ordering return of Garin’s license.
- On August 14, 1997, the trial court ruled Memorandum Circular No. TT-95-001 void ab initio for lack of quorum, held summary confiscation without hearing unconstitutional, made the injunction permanent, and enjoined further license confiscations without due process.
- MMDA appealed, reiterating that a driver’s license is a privilege subject to police power, not property, and that licensees had available avenues of appeal or fine payment.
Implementation of Memorandum Circular No. 04 (Series of 2004) and Mootness
- On Au