Agustin vs.

Edu
 President Ferdinand Marcos issued Letter of Instruction (LOI) No. 229, which
required all motor vehicles to secure early warning devices (EWD) consisting
of a pair of triangular, collapsible, reflectorized plates in red and yellow to be
purchased from the Land Transportation Commission. The purposes of this
LOI were to prevent accidents caused by vehicular obstructions and to adhere
to the road safety standards outlined in the 1968 Vienna Convention on Road
Signs and Signals, which the Philippines had ratified as per PD No. 207. In
compliance with such letter of instruction, the Commissioner of Land
transportation office issued Administrative order no. 1 directing the compliance
thereof. This petition alleged that such letter of instruction and subsequent
administrative order are unlawful and unconstitutional.
 Whether or not the letter of instruction No. 229 and the subsequent
administrative order issued is unconstitutional
 The SC ruled for the dismissal of the petition. The statutes in question are not
unconstitutional. These were definitely in the exercise of police power as such
was established to promote public welfare and public safety.
 The intent of the law in the assailed LOI is to prevent accidents, safeguard the
safety of the public, and adhere to the State's commitment to public
international law.
 The letter of instruction mentions, the resolutions of the 1968 Vienna
Convention on Road Signs and Signals and the discussions on traffic safety by
the United Nations- that such letter was issued in consideration of growing
number of road accidents due to stalled or parked vehicles on the streets and
highways.
 The Vienna Convention on Road signs and signals and the United Nations
Organization was ratified by the Philippine local legislation for the installation of
road safety signs and devices. It cannot be disputed then that this Declaration
of Principle found in the Constitution possesses relevance, between the
International law and municipal law in applying the rule municipal law prevail.