G.R. No. 194335 , November 17, 2020
SAMSON V. PANTALEON, EDUARDO A. TACOYO, JR., JESUS S. BAUTISTA AND MONICO C. AGUSTIN, PETITIONERS, VS. METRO MANILA DEVELOPMENT AUTHORITY, RESPONDENT.

FACTS

Petitioners are public utility bus drivers plying the SM Fairview-Baclaran route. Respondent Metro Manila Development Authority (MMDA), through its governing body the Metro Manila Council (MMC), issued MMDA Regulation No. 96-005 in 1996, establishing the Unified Vehicular Volume Reduction Program (UVVRP) or number coding scheme. A 1996 Memorandum of Agreement partially exempted buses of certain operators’ associations from the scheme. On October 15, 2010, the MMC adopted MMDA Resolution No. 10-16, re-implementing the number coding scheme for all public utility buses on an experimental basis from November 15, 2010, to January 15, 2011, citing recurring heavy traffic and rampant traffic violations by bus drivers. Subsequently, MMDA Chairman Francis N. Tolentino issued Memorandum Circular No. 08, Series of 2010, removing public utility buses from the list of vehicles exempted from the UVVRP. Petitioners filed a Petition for Injunction, seeking to enjoin the implementation of the number coding scheme on buses and to declare MMDA Resolution No. 10-16 and Memorandum Circular No. 08 null and void. They argued that the MMDA and MMC lack legislative or police powers and that the issuances constitute an invalid exercise of rule-making authority, encroach upon the powers of the Land Transportation Franchising and Regulatory Board (LTFRB) to regulate franchises, amend franchises without due process, and were implemented without the required approval from the Department of Transportation and Communications (DOTC).

ISSUE

Whether the Metro Manila Development Authority, through the Metro Manila Council, acted within its authority in issuing MMDA Resolution No. 10-16 and Memorandum Circular No. 08, Series of 2010, which re-implemented the number coding scheme (UVVRP) for public utility buses.

RULING

YES. The Supreme Court DENIED the petition and upheld the validity of the challenged MMDA issuances. The Court ruled that the MMDA, through the MMC, possesses the authority to promulgate the number coding scheme as a regulation to manage metro-wide traffic, which is within its mandate under Republic Act No. 7924 . The law grants the MMDA the power to implement and enforce policies, standards, rules, and regulations for the delivery of metro-wide services, including transport and traffic management. The number coding scheme is a valid exercise of this administrative, rule-making power aimed at addressing traffic congestion. The Court found that the scheme does not amend or revoke the franchises issued by the LTFRB. A franchise is a privilege to operate, not a guarantee of a specific volume of business or immunity from reasonable traffic regulations. The coding scheme is a general traffic regulation that applies to all specified vehicles and does not single out or alter the terms of a Certificate of Public Convenience. Furthermore, the regulation is a valid exercise of the State’s police power, enacted to promote public safety, order, and convenience by alleviating traffic congestion. The temporary and experimental nature of the re-implementation also indicates a reasonable approach to addressing traffic concerns. The Court concluded that the MMDA acted within its statutory authority and that the issuances were not unconstitutional or invalid.