Manila Development Authority v. Garin, G.R. No.

130230, 15 April 2005

Facts:

Dante O. Garin, a lawyer, was issued a traffic violation receipt (TVR) and his driver's license
confiscated for parking illegally along Gandara Street, Binondo, Manila, on 05 August 1995.
Before the expiration of his TVR validity, he addressed a letter to then Metro Manila
Development Authority (MMDA) Chairman Prospero Oreta requesting the return of his
driver's license, and expressing his preference for his case to be filed in court. No response
was received hence, he filed petition for PI in the RTC citing Sec. 5(f) of Rep. Act No. 7924
grants the MMDA unbridled discretion to deprive erring motorists of their licenses, pre-
empting a judicial determination of the validity of the deprivation, thereby violating the due
process clause of the Constitution. The Preliminary Injucntion was granted and MMDA
ordered to return the Driver's licence. RTC ruled in favor of Garin, hence, this present
petition.

Issue:

WON MMDA has power to confiscate Driver's License?

Ruling:

No. The MMDA is not a local government unit or a public corporation endowed with
legislative power, and, unlike its predecessor, the Metro Manila Commission (which is an
LGU during Marcos time), it has no power to enact ordinances for the welfare of the
community. insofar as Sec. 5(f) of Rep. Act No. 7924 is understood by the lower court and by
the petitioner to grant the MMDA the power to confiscate and suspend or revoke drivers'
licenses without need of any other legislative enactment, such is an unauthorized exercise of
police power. Thus, where there is a traffic law or regulation validly enacted by the
legislature or those agencies to whom legislative powers have been delegated (the City of
Manila in this case), the petitioner is not precluded – and in fact is duty-bound – to confiscate
and suspend or revoke drivers' licenses in the exercise of its mandate of transport and traffic
management, as well as the administration and implementation of all traffic enforcement
operations, traffic engineering services and traffic education programs, but in the present
case, there is none.