UP LAW BGC EVE 2

Case name Leovillo C. Agustin, petitioner, vs Hon. Romeo F. Edu, et. al, respondents

GR No|Date G.R. No. L-49112 | February 2, 1979

Topic Inherent Powers of the State: Police Power

Ponente Fernando, J.

Doctrine The inherent police power of the state is the “authority to enact legislation that may interfere with personal liberty or property in order to
promote the general welfare. Persons and property could thus be subjected to all kinds of restraints and burdens in order to secure the general
comfort, health and prosperity of the state.

Facts
● President Marcos issued a Letter of Instruction mandating the installation of early warning device as a pre-
registration requirement for motor vehicles. This mandate was based on the statistics of vehicular accidents caused by
stalled or parked motor vehicles along the streets and highways without the appropriate early warning device to signal
other motorists of their presence.
● Pursuant to this Letter of Instruction, Respondent Romeo Edu, as the Land Transportation Commissioner issued
the implementing rules and regulations for the said mandate.

Ratio
Decidendi

Whether or not the Letter of Instruction is unconstitutional?

No. The Letter of Instruction in question was issued in the exercise of the police power of the State. A consequence of this
sovereign power is to control and prohibit certain acts, which may impair the liberty of individuals, for the sake of the
general welfare of society. As quoted by the Court in the case of Calalang vs Williams, police power of the state is the
“authority to enact legislation that may interfere with personal liberty or property in order to promote the general welfare.
Persons and property could thus, be subjected to all kinds of restraints and burdens in order to secure the general comfort,
health and prosperity of the state.” In the case at bar, the Petitioner contended that the Letter of Instruction was contrary to
the due process and equal protection safeguards of the Constitution. However, as held by the Court, the legislation in
question was for the promotion of safe transit and public welfare, i.e. with the installed early warning devices, premature
deaths from possible vehicular collisions will be avoided. So, even if the said law imposed a heavy burden on the
petitioner, it must be noted that the police power of the state is an inherent and plenary power that can be used to enact
measures to “insure communal peace, safety, good order, and welfare.” From the foregoing, it can be concluded that the
Letter of Instruction was therefore within the bounds of the inherent powers of the sovereign state and is constitutional.

Ruling
Wherefore, the Court ruled against petitioner. It maintained that the Letter of Instruction and the corresponding
implementing rules and regulations are valid and constitutional.