G.R. No. 102782 December 11, 1991
THE SOLICITOR GENERAL, et al. vs. THE METROPOLITAN MANILA AUTHORITY and THE MUNICIPALITY OF MANDALUYONG

FACTS

This case originated from the Court’s 1990 decision in Metropolitan Traffic Command v. Gonong, which held that Presidential Decree No. 1605 did not authorize the confiscation of driver’s licenses or the removal of license plates for traffic violations in Metro Manila, except under specific conditions for stalled vehicles per Letter of Instruction No. 43. Following this final judgment, the Court received numerous complaints from motorists, including the named petitioners, alleging that traffic enforcers from various Metro Manila localities continued to confiscate licenses and detach plates. In response, the respondents defended their actions. The Municipality of Mandaluyong cited its Ordinance No. 7, Series of 1988, while the Metropolitan Manila Authority (MMA) invoked its subsequently enacted Ordinance No. 11, Series of 1991, which explicitly authorized the detachment of license plates and impoundment of illegally parked vehicles.

ISSUE

Whether Ordinance No. 11 of the MMA and Ordinance No. 7 of Mandaluyong, which authorize the confiscation of driver’s licenses and the removal of vehicle license plates for traffic violations, are valid.

RULING

The Supreme Court declared both ordinances null and void. The legal logic is anchored on the principle of statutory supremacy and the limits of delegated legislative power. PD 1605, a special law governing traffic violations in Metro Manila, explicitly enumerates the permissible penalties, which do not include the confiscation of driver’s licenses or the detachment of license plates (except as per LOI 43 for stalled vehicles). The Court, in Gonong, had already interpreted this as a prohibition. When a national law is clear and specific, local government units, exercising delegated legislative authority, cannot contravene it. The challenged ordinances did not merely supplement PD 1605; they directly violated it by imposing sanctions the law does not allow. Consequently, they constitute an invalid exercise of delegated power, as an agent (the local authority) cannot act contrary to the will of the principal (Congress). The Court acknowledged the laudable intent behind the ordinances to address traffic congestion but emphasized that the remedy lies with Congress to amend PD 1605, not with local bodies to disregard it. All law enforcement authorities in Metro Manila were enjoined from imposing these unauthorized sanctions.