Statutory Deconstruction: The Battle for Traffic Management Supremacy

It is very interesting to read a case where the Supreme Court has to analyze laws that are distinct yet closely related to one another in order to resolve a justiciable issue. The recently released case of FEJODAP et. al. vs. Government of Manila et. al. and the Metro Manila Development Authority (G.R. No. 209479 , July 11, 2023) is one such case and it concerns the authority of LGUs to issue tickets for traffic violation and confiscate licenses. Sounds a little mundane, if you will think about it, but the implications of not addressing this matter are calamitous given that traffic has been a perineal head scratcher in Metro Manila for as long as cars existed.

In this case, the Court had to resolve the issue of who between the MMDA and the LGUs in Metro Manila are empowered to issue traffic tickets and confiscate driver’s licenses from erring motorists. Apparently, there has been a standing ten-year legal battle in the stage of traffic management between the MMDA versus ALL the cities (except Malabon), including the Municipality of Pateros, in Metro Manila. In order to go about this scuffle, the Supreme Court had to dissect and deconstruct three (3) laws that seemingly conflict one another, namely:

(i) Republic Act No. 4136 or the “LTO Law” which vests to the Land Transportation Office the power to establish and prescribe rules and regulations for the enforcement traffic laws, and this includes the power to confiscate licenses and issue traffic violation tickets;

(ii) Republic Act No. 7160 or the “Local Government Code” or the “LGC” grants the exclusive power to all cities and lone municipalities in Metro Manila to regulate and manage traffic within their respective territorial jurisdictions and issue ordinances pursuant to such mandate; and

(iii) Republic No. 7924 or the “MMDA Law” bestows to the MMDA the duty to install and administer a single ticketing system, including the power to confiscate licenses from erring drivers, throughout Metro Manila.

Evidently, these laws are contending each other as each one designates different agencies or local governments that are primarily tasked to enforce traffic. According to the LTO Law, LTO has the power to regulate traffic rules. The LGC states that the LGUs have the exclusive power to do so within their respective territories. The MMDA Law holds the MMDA as the entity with the power to enforce traffic rules, as well as implement the single ticketing system.

Although this is quite a triple threat of conflict of laws, for purposes of this article, we will focus on the conflicting provisions between the LGC and the MMDA Law. Fortunately, the final arbiter on interpreting laws belongs to the Supreme Court, and the ruling they issued was based on time-honored principles of statutory construction, presumably because that is the only way this issue can be resolved. By simply reading the law and analyzing their respective contents, comparing them side-by-side, unearthing the intention behind the language used, and coming up with a logical conclusion that meets the standard of fairness, reason and equity for all parties involved.

The parties in this case are government agencies and local governments, all interested in upholding their legitimate statutory objectives to ease traffic in the capital metro. However, there can only be one captain of this ship and the Supreme Court ruled that it is the MMDA that will reign as the primary authority in traffic enforcement in Metro Manila. More specifically, the Supreme Court held that the MMDA is the only entity in Metro Manila who can issue tickets for traffic violations and confiscate licenses from motorists. The LGUs, on the other hand, get to participate in traffic management within their respective territories but they cannot issue tickets or confiscate licenses, unless they are deputized by the MMDA.

In ruling in favor of the MMDA, the Supreme Court employed basic principles of law which comes in the form of statutory construction. By relying on elementary tenets of law, the Supreme Court did not only judiciously interpret the laws, but the Court was able to harmonize the contradiction in a sense that inspires repose and without undermining the respective policies enshrined in each of the contending laws.

Statutory construction (or StatCon) is a tool used by lawyers and judges to dissect the laws and interpret the meaning they express or even imply. Very interestingly, one of the approaches the Supreme Court employed was based on the principle of time. Generally, the law with the latest enactment date gains primacy over the older laws. In this case, the MMDA Law is the latest law among the three having been enacted in 1995. Evidently, the MMDA Law was passed decades later than the LTO Law which was enacted in 1964. The MMDA Law was signed 4 years later than the LGC which was passed in 1991. The Supreme Court rationalized this approach by ruling that the MMDA Law’s provisions contain “the later expression of legislative will.”

Considering that the MMDA Law is the latest expression of law as regards the matter of traffic enforcement in Metro Manila, its contents carry supervening effects to other related laws; hence, the resulting impact is the implied modification of the contradicting provisions in the LGC. Holding to this position, the MMDA Law effectively amends the LGC in that its provisions only empower the cities (and Pateros) in Metro Manila to regulate traffic to the extent that they do not conflict with the regulations issued by the MMDA. Since the MMDA already issued a regulation on single ticketing system, the various ordinances in each of the cities in Metro Manila enabling their respective traffic enforcers to issue traffic tickets and confiscate licenses should no longer be enforced.

Additionally, the Supreme Court also applied the Verba Legis Rule or the “Plain Meaning” Doctrine, which means that when the words and phrases of the statute are clear, their meaning must be determined from the language employed and the statute must be taken to mean exactly what it says. This is probably, in my opinion, the most direct to the point and self-explanatory rule in statutory construction. If the earlier discussion is based on time, this one is based on simple logic. Indeed, if the words of the statute are clear, what else are we supposed to do with the law but to apply its expression. Period. 

It must be understood that the reason why the Verba Legis Rule was used is because there is a specific provision in the MMDA Law inferring the exclusivity of the MMDA’s authority to enforce traffic laws, and that the LGUs in Metro Manila may participate in such functions only when their traffic enforcers are deputized by the MMDA. Notice how the authority is evident on to the MMDA over the local governments. Section 5 of the MMDA Law, states: 

"Sec. 5. Functions and powers of the Metro Manila Development Authority. - The MMDA shall: 

xxx

Install and administer a single ticketing system, fix, impose and collect fines and penalties for all kinds of violations of traffic rules and regulations, whether moving or non-moving in nature, and confiscate and suspend or revoke driver's licenses in the enforcement of such traffic laws and regulations, the provisions of RA 4136 and PD 1605 to the contrary notwithstanding. For this purpose, the Authority shall enforce all traffic laws and regulations in Metro Manila, through its traffic operation center, and may deputized members of the PNP, traffic enforcers of local government units, duly licensed security guards or members of non-governmental organizations to whom may be delegated certain authority, subject to such conditions and requirements as the Authority may impose.

While both the MMDA Law and the LGC relate to traffic management, the MMDA Law had a specific edge over the LGC on account of this provision that bestows to the MMDA authority to enforce traffic laws across Metro Manila and deputize LGUs to participate in traffic enforcement. In other words, the LGUs are incapable of enforcing traffic laws without the imprimatur of the MMDA. The fact that the MMDA Law counters the provisions of the LGC is inconsequential due to the express provision in the MMDA Law empowering the MMDA to control traffic to the extent that it can give or withhold such power from other agencies, including the local governments. Since that provision of the MMDA Law is crystal clear, there is nothing left for the Supreme Court to do but to apply it in this case and uphold the language used by the MMDA Law.

Finally, the Supreme Court went beyond the letter of the MMDA Law and delve into the intent of the legislature in granting the power to regulate traffic in Metro Manila with the MMDA. Yes, that’s right! The intent of our honorable congressmen and senators were taken into consideration in the process of statutory construction. Whatever is between the ears of Robin Padilla and Lito Lapid are all accounted for here. Jokes aside, bringing to light the legislative intent behind the law is probably the most important aspect in statutory construction. In most cases, intent almost always plays a crucial part in determining complex legal issues, such as in Criminal Law, for instance. In this case, by reviewing the deliberations of the House Committee on Local Government, it was revealed that the intent of Congress in crafting the MMDA Law was for the MMDA to have rule-making powers in relation to traffic management in Metro Manila.

When Congress granted the MMDA the power to promulgate rules for traffic enforcement by virtue of the MMDA Law, the Supreme Court saw this as a valid delegation of legislative powers. In essence, the intent is that Congress bestowed its law-making power to MMDA because of its special competence in handling traffic issues in Metro Manila. As opposed to the general scope of the local governments to promote the welfare of their constituents, incidentally including traffic enforcement, the specific and special endowment of traffic handling is intentionally bestowed with the MMDA. Notably, that same special intent was never found in the LGC.

Even when the hammer fell against the local governments in Metro Manila, the Supreme Court remained graceful in its ruling. Despite removing the power to issue traffic tickets and confiscating licenses, the Supreme Court still recognized the autonomy of every local government and that they are free to continue with their avowed duty to their local citizens. More importantly, the Court pointed out that the city mayors themselves in Metro Manila can indirectly control the policies of the MMDA through the veil of the Metro Manila Council – the policy making body of the MMDA - in which they are members. As held in the case:

“[The Metro Manila Council’s] structure breathes life to the avowed objectives of the MMDA Law which is to promote efficiency, cohesion, harmony, and order in the delivery of metro-wide services such as traffic management in Metro Manila – without undermining local autonomy – as its decisions are reached through a governing body composed of the local chief executives themselves.”

This statement reveals both irony and depth. The intent behind the MMDA Law was never to pit the cities and the MMDA against each other in the management of traffic in Metro Manila. Instead, it was enacted to synchronize the functions of the constituent cities through the formation of the Metro Manila Council that directs the policies of the MMDA. Consequently, the expectation is for the city mayors – who are members of the MMC – to collaborate in order to formulate a unified policy that effectively transcends their individual jurisdictions and, in effect, benefits their respective territories in a cohesive manner.

As of this date, the MMDA, in conjunction with the MMC, stands as the most adept agency for overseeing all aspects of traffic enforcement in Metro Manila. This assertion becomes particularly evident when considering the proposed implementation of a single-ticketing system by the agency. In stark contrast, decentralizing this authority to individual cities would prove highly inefficient in traffic management, as each city would likely adopt (and has adopted) varying ticketing system for traffic violations. Utter confusion is abound in this form of ticketing system.

Moreover, the prospect of license confiscation undertaken by each city within their territories becomes a potential source of chaos. Picture an improbable scenario where your license is confiscated in Las Piñas, but you reside in Quezon City. The inconvenience arising from this lack of uniformity could pose significant challenges to a society aspiring for operational and regulatory efficiency.

The point is that the Supreme Court, in its final statement in the case, was able to shine the light on the ultimate purpose of the MMDA. Notably, the participation of each constituent city in Metro Manila in traffic management through the MMC serves to reinforce, rather than compromise, the local autonomy of these individual cities. Indeed, the collaborative efforts within the MMC should contribute to the enhancement of local autonomy for each city within Metro Manila not only in regards to traffic management, but also to other metro-wide concerns such as cleanliness, infrastructure, flood control, health and public safety.