G.R. No. L-49112 February 2, 1979
LEOVILLO C. AGUSTIN, petitioner, vs. HON. ROMEO F. EDU, in his capacity as Land Transportation Commissioner; HON. JUAN PONCE ENRILE, in his capacity as Minister of National Defense; HON. ALFREDO L. JUINIO, in his capacity as Minister Of Public Works, Transportation and Communications; and HON. BALTAZAR AQUINO, in his capacity as Minister of Public Highways, respondents.

FACTS

Petitioner Leovillo C. Agustin, owner of a Volkswagen Beetle equipped with built-in blinking lights, assailed the constitutionality of Letter of Instruction (LOI) No. 229 (as amended by LOI No. 479) issued by President Ferdinand E. Marcos. The LOI mandated all motor vehicle owners to procure and use a specific reflectorized triangular early warning device (EWD) when a vehicle is stalled or parked on highways. The Land Transportation Commissioner, respondent Romeo F. Edu, issued implementing rules (Memorandum Circular No. 32) requiring the EWD as a condition for vehicle registration. Petitioner contended that his vehicle’s existing safety features were sufficient, rendering the mandatory purchase of the prescribed EWD oppressive, arbitrary, and confiscatory. He argued the measure imposed a staggering financial burden on the public without a demonstrated imperative need, thereby violating due process.

ISSUE

Whether LOI No. 229, as amended, and its implementing rules constitute a valid exercise of police power, or whether they are unconstitutional for being oppressive, arbitrary, and a violation of due process and the non-delegation principle.

RULING

The Supreme Court upheld the validity of LOI No. 229 and its implementing rules as a legitimate exercise of the state’s police power. The Court emphasized that police power is plenary and can be delegated to the President under the 1973 Constitution, which was in force at the time. The objective of the LOI—to enhance road safety by providing a standardized, highly visible warning signal for stalled vehicles—is a paramount public interest that justifies the regulation. The Court ruled that the means prescribed (specific EWD specifications) are reasonably necessary to achieve this objective, as standardization ensures immediate recognition by motorists, thereby reducing collision risks. The fact that some vehicles have built-in blinking lights does not negate the reasonableness of requiring a uniform, reflectorized device that remains operational without battery power. The financial cost, while not insignificant, is a valid imposition incidental to the exercise of police power for public safety. The implementing rules issued by respondent Edu were deemed a valid administrative implementation, not an undue delegation of legislative power. Consequently, the petition was dismissed for lack of merit.