G.R. No. 209479, July 11, 2023
FEDERATION OF JEEPNEY OPERATORS AND DRIVERS ASSOCIATION OF THE PHILIPPINES (FEJODAP), ET AL., PETITIONERS, VS. GOVERNMENT OF MANILA CITY, ET AL., RESPONDENTS.

FACTS

Petitioners, various transport operators and drivers associations, filed a petition challenging the common provisions of the traffic ordinances enacted by respondent Local Government Units (LGUs) in Metro Manila. They argued that these ordinances caused confusion due to varying traffic tickets, fines, and penalties, conflicting with the Metropolitan Manila Development Authority’s (MMDA) mandate. The Majority Decision struck down the assailed ordinances as void, ruling that the MMDA Law (Republic Act No. 7924) bestowed upon the MMDA the rule-making power for traffic regulation in Metro Manila, which impliedly modified the relevant provisions of the Local Government Code (LGC). The dissenting opinion of Justice Lazaro-Javier addresses this conclusion.

ISSUE

Whether the petition has been rendered moot by the adoption of the Metro Manila Traffic Code (MMDA Resolution No. 23-02) providing for a unified ticketing system; and, on the merits, whether the MMDA Law deprived the component LGUs of their quasi-legislative power to enact ordinances regulating traffic within their respective territories.

RULING

The Dissenting Opinion votes to DISMISS the petition on the ground of mootness and, alternatively, to UPHOLD the traffic regulatory power of the LGUs.
1. On Mootness: The case has been rendered moot by a supervening event—the adoption by the Metro Manila Council of MMDA Resolution No. 23-02, the “Metro Manila Traffic Code.” This Code established a unified ticketing system and standardized penalties for traffic violations in Metro Manila, directly addressing the petitioners’ core grievance regarding confusion and disorder from varying LGU ordinances. A moot case is one where a supervening event terminates the legal issue, leaving the Court with nothing to resolve.
2. On the Merits (Alternative Ruling): The MMDA is a mere administrative coordinating body without ordinance-making power. The power to enact traffic ordinances remains with the LGUs under Sections 447(5)(v-vi) and 458(5)(v-vi) of the LGC, which explicitly authorize them to regulate traffic on streets within their territories. The MMDA Law does not divest LGUs of this power.
* The MMDA’s functions under Section 3(b) and Section 5(e) and (f) of its charter are purely coordinative, administrative, and policy-making in nature. They involve formulating policies, coordinating and monitoring programs, and implementing and enforcing existing traffic laws and regulations, including through a single ticketing system.
* The terms “formulate policies, standards, and programs” in the MMDA Law refer to aids or guides for legislative bodies and are not self-executing rules or regulations.
* The MMDA Law and the LGC can be harmoniously construed. The MMDA sets metro-wide policies and coordinates enforcement, while the LGUs retain their legislative autonomy to enact localized traffic ordinances. There is no implied repeal or modification of the LGC provisions by the later-enacted MMDA Law, as the statutes are not patently inconsistent and have coexisted for decades.
* This interpretation aligns with legislative intent, as evidenced by Congressional deliberations which emphasized protecting LGU autonomy, and is supported by settled jurisprudence characterizing the MMDA as a coordinating body.