SOLICITOR GENERAL v. METROPOLITAN MANILA AUTHORITY (MMA), 204 SCRA 837 (Digested Case)

SOLICITOR GENERAL v. METROPOLITAN MANILA AUTHORITY (MMA)

Re: General welfare clause (Sec. 16, LGC 1991)

FACTS: In the Gonong Case 1990, the Court held that the confiscation of the license plates of motor vehicles for traffic violations was not among the sanctions that could be imposed by the Metro Manila Commission under PD 1605. It was there also observed that even the confiscation of driver's licenses for traffic violations was not directly prescribed by the decree nor was it allowed by the decree to be imposed by the Commission. In the case at bar, the MMA issued an ordinance authorizing itself to detach the license plate/tow and impound attended/ unattended/ abandoned motor vehicles illegally parked or obstructing the flow of traffic in Metro Manila. On the other hand, private petitioners herein contended that the ordinance passed by MMA and the provisions of the decision in the Gonong Case were conflicting. The MMA argued that there was no conflict between the two. It stressed that the decision itself said that the confiscation of license plates was invalid in the absence of a valid law or ordinance, which was why the ordinance was enacted. The Authority also pointed out that the ordinance could not be attacked collaterally but only in a direct action challenging its validity.

ISSUES:

(1) WON the ordinance cannot be attacked collaterally.

(2) WON there was valid delegation of legislative power to MMA.

(3) WON the ordinance of MMA is valid.

HELD:

(1) Yes. The Metropolitan Manila Authority is correct in invoking the doctrine that the validity of a law or act can be challenged only in a direct action and not collaterally. That is indeed the settled principle. However, that rule is not inflexible and may be relaxed by the Court under exceptional circumstances, such as those in the present controversy.

(2) Yes. The Court holds that there is a valid delegation of legislative power to promulgate such measures, it appearing that the requisites of such delegation are present. These requisites are. 1) the completeness of the statute making the delegation; and 2) the presence of a sufficient standard. But the problem before us is not the validity of the delegation of legislative power. The question we must resolve is the validity of the exercise of such delegated power.

(3) No. A careful study of the Gonong decision will show that the measures under consideration do not pass the first criterion because they do not conform to existing law. The pertinent law is PD 1605. PD 1605 does not allow either the removal of license plates or the confiscation of driver's licenses for traffic violations committed in Metropolitan Manila. There is nothing in the following provisions of the decree authorizing the Metropolitan Manila Commission (and now the Metropolitan Manila Authority) to impose such sanction. MMA and LGUs are mere agents vested with what is called the power of subordinate legislation. As delegates of the Congress, the local government unit cannot contravene but must obey at all times the will of their principal. In the case before us, the enactments in question, which are merely local in origin, cannot prevail against the decree, which has the force and effect of a statute.