G.R. No. 130230 ; April 15, 2005
Metropolitan Manila Development Authority, Petitioner, vs. Dante O. Garin, Respondent.

FACTS

Respondent Dante O. Garin, a lawyer, was issued a traffic violation receipt (TVR) and his driver’s license was confiscated by MMDA personnel for illegal parking on August 5, 1995. The TVR directed him to report to the MMDA after 48 hours and stated that a criminal case would be filed if the license was not redeemed within 30 days. Garin wrote to the MMDA Chairman requesting his license’s return and for his case to be filed in court instead. After receiving no reply, he filed a complaint in the Regional Trial Court (RTC) of Parañaque. He argued that Section 5(f) of Republic Act No. 7924 , which authorizes the MMDA to confiscate and suspend or revoke licenses, granted unbridled discretion without implementing rules, violating due process and constituting an undue delegation of legislative power.
The RTC ruled in favor of Garin. It declared MMDA Memorandum Circular No. TT-95-001, which authorized the confiscation, void for lack of a quorum during its passage. The court also held that the summary confiscation of a driver’s license without a hearing deprived Garin of a property right without due process. It made the preliminary injunction permanent, ordered the return of Garin’s license, and directed the MMDA to desist from such confiscations. The MMDA elevated the case to the Supreme Court, arguing that a driver’s license is a privilege subject to regulation and that the confiscation was a valid exercise of its powers under its charter.

ISSUE

Whether Section 5(f) of Republic Act No. 7924 , authorizing the MMDA to confiscate and suspend or revoke driver’s licenses in the enforcement of traffic laws, is constitutional.

RULING

The Supreme Court ruled that Section 5(f) of R.A. No. 7924 is unconstitutional. The Court clarified that the MMDA is not a local government unit or a public corporation endowed with police power and legislative authority. It is a development authority with purely administrative functions and technical implementation duties for metro-wide services. The power to enact traffic regulations and impose corresponding penalties is legislative in nature. This power resides in the legislative bodies of the local government units within Metro Manila and the Congress of the Philippines. The charter of the MMDA did not grant it police power, let alone legislative authority. Therefore, Section 5(f), which effectively allowed the MMDA to exercise such power through license confiscation and the imposition of fines, constituted an invalid delegation of legislative power. The MMDA’s act of confiscating driver’s licenses without a hearing also violated procedural due process. The Court affirmed the RTC decision, upholding the permanent injunction against the MMDA’s confiscation practice under the void provision.