October 12, 2020

ATTY. CLEARANCE V. GUINTO, CSEE

Acting Director,
Law Enforcement Services
Land Transportation Office
Central Office, East Ave.,
Diliman, Quezon City.

ATTENTION : Atty. Roberto A. Valera

Deputy Director
Law Enforcement Service

SUBJECT : Comments and recommendations on Republic Act No. 10916- An

Act Requiring the Mandatory Installation of Speed Limiter in
Public Utility and Certain Types of Vehicle otherwise known as the
"Road Speed Limiter Act of 2016".

Dear Director Guinto:

This refers to Republic Act No. 10916 otherwise known as the "Road Speed Limiter Act of 2016"
which requires the mandatory installation of speed limiter in public utility and certain types of
vehicles. It explicitly provides that covered vehicles must have speed limiters installed as a
requirement to register with the Land Transportation Office (LTO) or apply a franchise from
Land Transportation Franchising and Regulatory Board (LTFRB) otherwise, it will not be allowed
to run in any road, street or highway in the Philippines.

Accordingly, the mandated speed limiter are designed to reduce accidents by limiting the
maximum speed of a vehicle by restricting fuel supply to the engine through the installation of
mechanical, electronic, or communications system or the combination of these similar devices
performing the same function which aims to pursue a more proactive and preventive approach
to revolutionize road safety.   

Driving over the speed limit is among the most common reasons of  vehicular accidents and this
often called as "Highway Killer" because of the attributed number of fatalities and serious
injuries. In the case of Reinoso v. CA, a collision between a passenger jeepney and a truck
caused the death of the jeepney passenger and it was established that the primary cause of the
injury or damage was the negligence of the truck driver who was driving it at a very fast speed.
Moreover, in one case the Supreme Court has appreciated that "Speeding is indicative of
imprudent behavior because a motorist is nevertheless expected to exercise ordinary care and
drive at a reasonable rate of speed commensurate with all the conditions encountered  which
will enable him to keep the vehicle under control and whenever necessary to put the vehicle to
a full stop to avoid injury to others using the highway xxx it must be stressed that restriction on
speed assumes more importance".1

In view of the foregoing, the following are recommendations that are of paramount
considerations in order to sufficiently achieve the policy goals mandated by the above-
mentioned law viz;

1) High definition automated CCTV speed cameras should be installed at a particular

road related crash risk and/or in common congested points on highways to have a
visible control in one place and to easily trace violators.

1
Caminos, Jr. vs. People ,G.R. No. 147437, May 8, 2009

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 2) A close inter-agency and local government coordination should be develop for
speed management strategy. Local Government Units (LGU's) should be given an
adequate budget to procure speed limit guns because they play an important role
in informing the public of the dangers brought by driving beyond the maximum
limit and the existence of law mandating the use of speed limiters.

3) Under RA 4136 otherwise known as the "Land Transportation and Traffic Code"
there are specified maximum allowable speeds on various national roads which
was not taken into consideration by RA 10916 because the efficiency of the speed
limiters would depend upon the speed limits set forth for by the law.

4) Another useful measure is to require vehicle manufacturers to install a speed

limiter (SL) device that is linked with the system regulated by LTO and other
related agencies in order for the government to incur less expenses and for easy
evaluation and data gathering associated to the implementation of the mandated
SL as well to avoid congestion in testing/installing sites.

5) Installation of the mandated speed limiters (SL) should be limited to newer motor
vehicles (ex. 2000-present) as older vehicles may lack innovative technology to
install the SL properly which may lead to severe accidents.

In view of the foregoing, vehicles must be a speed limiter compliant to constrain the vehicles to
travel with their predetermined speed limits

Respectfully submitted.

(SGD.) ROSEMARIE C. ARNAIZ

Applicant

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