15 September 2022

ATTY. TEOFILO E. GUADIZ III, CESO V

Assistant Secretary
Land Transportation Office
East Avenue, Quezon City

Assistant Secretary:

Respectfully submitting to your good Office our comments to the draft of the
Memorandum on the Revised Procedure in the Distribution of License Plates, in
compliance with Memorandum Circular dated 06 September 2022.

For your perusal.

Thank you.

Respectfully Yours,

EDUARDO C. DE GUZMAN
Regional Director
 COMMENT ON THE DRAFT OF MEMORANDUM CIRCULAR ON THE
REVISED PROCEDURE IN THE DISTRIBUTION OF LICENSE PLATES
AND RFID STICKERS TO OWNERS OF NEWLY REGISTERED BRAND-NEW
MOTOR VEHICLES (MVs) AND MOTORCYCLES (MCs)

BACKGROUND

LTO Regional Office New Registration Unit (NRU) and the other District Offices with
NRU currently have a smooth sailing process in the initial registration of motor vehicles
and issuance of license plates. The only interruption is when the scanner of the bar code
in the license plate is malfunctioning.

The only issues being confronted by the NRU are 1) the failure of the dealers to deliver
the backlog of plates to motorcycle owners as some of the latter are unlocated and 2) the
unavailability of replacement plates.

Overall, there is no problem with the current set up in the initial registration and
issuance of plates to newly registered motor vehicles and motorcycles.

COMMENTS

The revision of the procedure revolves around this statement in the draft:

“THE REGIONAL OFFICES THROUGH THEIR SUPPLY OFFICERS SHALL

DISTRIBUTE THE LICENSE PLATES AND RFID STICKERS TO THE NEAREST
DISTRICT/EXTENSION OFFICES WHERE THE REGISTERED OWNER RESIDES
WHICH INFORMATION HAS BEEN OBTAINED FROM THE REGISTRATION
DOCUMENTS SUBMITTED BY THE DEALERSHIP.”

Following the line of rationalization, our Office provides the following comments noted
on the draft of the Revised Procedure in the Distribution of License Plates and RFID
Stickers to owners of newly registered brand-new motor vehicles (MVs) and motorcycles
(MCs):

1. MANPOWER. The matter that may be taken in consideration is the burden and
additional work assigned to District Offices. The District Offices with no new
registration function must not be tasked to carry out the duties of distributing
plates to the owners. Aside from the fact that we have insufficient Job Orders, it
is impracticable to assign additional job to an employee to inform and contact the
owners of the plates.

2. HEAVY WORKLOAD ON THE PART OF DISTRICT OFFICE. Currently, District

Offices are swarmed by clients and loaded with work because of the voluminous
backlogs and delays caused by the frequent system offline status and major IT
issues. Assigning an additional job to District Officers to distribute plates will be
inefficient. This duty must be retained to the employees of New Registration
Unit. We must limit the job given to the employees within the District Level
necessary to perform their primary function of licensing and registration renewal
transaction.

Also, the proposed new procedure may cause crowding in District Offices as the
end-users or clients will start asking updates from LTO employees.
 3. DIFFICULTY IN MONITORING. It is burdensome to identify the addresses of
the registrants and determining the nearest District Offices where the plates shall
be assigned. The distribution of plates may be unmanageable and disorderly
because it is decentralized and scattered unlike when NRU is the only unit that
will take charge of the duty.

It is anticipated that this new process of plate distribution will be more

disorganized when the owner of the motor vehicle or motorcycle resides in
another region because the owner who resides in another region still needs to go
the Regional Office which has the Geographical Area of Responsibility (GAOR)
over the registering NRU.

4. NO ASSURANCE OF ACCURATE ADDRESS. In the draft of the new procedure,

the address of the client plays a primordial factor in determining what District
Office the license plates shall be assigned to. The problem that may arise here is
the inaccuracy of the address provided.

During initial registration, the motor vehicle registrants directly transact with the
dealer and not with the LTO NRU. As such, we cannot fully rely on the addresses
provided as the causal element to determine to where the plates be turned over.

In view of the foregoing, the Office is not amenable with the proposed draft. As initially
stated, there is no problem with our current process in cascading of plates. The only
unavoidable situation and persisting problem is the distribution of backlogs of
motorcycle plates and the suggested new process may not also be effective in resolving
such issue.

Thank you.

Prepared by:

ATTY. SUSHEN JIMBEL MARIZ M.

SISON
Officer-in-Charge, Operations Division

Noted and approved:

EDUARDO C. DE GUZMAN
Regional Director