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Solicitor General v. Metropolitan Manila Authority

G.R. No. 102782, December 11,1991
CRUZ, J

Facts:

 Rodolfo A. Malapira allegedly committed a traffic violation and his driver's license was confiscated by
Traffic Enforcer in Quezon City.
 The Caloocan-Manila Drivers and Operators Association sent a letter to the Court asking who should
enforce the decision in the above-mentioned case, whether they could seek damages for confiscation of
their driver's licenses, and where they should file their complaints.
 Stephen L. Monsanto, also complained against confiscation of his driver’s license by a Traffic Enforcer in
an alleged traffic violation in Mandaluyong and Makati respectively.
 Dan R. Calderon complained against confiscation of his driver’s license by the Makati Police Force in an
alleged traffic violation in Makati.
 Grandy N. Trieste also protested the removal of his front license plate and confiscation of his driver’s
license.
 Metropolitan Manila Authority issued Ordinance No. 11, Series of 1991, 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."
 Metropolitan Manila Authority of Ordinance No. 11, Series of 1991 appears to be in conflict with the
decision of the Court in the case at bar (as reported in 187 SCRA 432), where it was held that the license
plates of motor vehicles may not be detached except only under the conditions prescribed in LOI 43.

 Metropolitan Manila Authority offers its comment and defended the said ordinance. The Authority argued
that there was no conflict between the decision and the ordinance because the latter was meant to
supplement and not supplant the latter.

Issue:

Whether or not Ordinance implemented by the MMA is Valid

Ruling:

No it is not valid. The policies under discussion fail the first criterion because they do not follow the law, as shown
by a comprehensive analysis of the Gonong decision. The relevant statute is PD 1605. For traffic infractions
committed in Metropolitan Manila, PD 1605 prohibits both the confiscation of driver's licenses and the removal of
license plates. The Metropolitan Manila Commission (and, later, the Metropolitan Manila Authority) are not given
any authority to levy such a penalty by the following clauses of the order. LGUs and MMA are only agents who
have access to the so-called authority of subordinate legislation. The local government unit must always comply
with the wishes of their principal since they are representatives of the Congress and cannot do otherwise. In the
issue at hand, the enactments in question—which are simply local in nature—cannot outweigh the decree, which
has the same legal authority as a statute.