SC Upholds MMDA’s Authority; Dismisses Petition for Injunction Against Traffic Scheme

June 17, 2021

The Supreme Court, voting unanimously, upheld the authority of the Metro Manila Development Authority (MMDA) to enforce measures to curb traffic congestion in Metropolitan Manila as it dismissed the petition for injunction filed in 2020 by bus drivers to stop the re-implementation of the MMDA’s number coding scheme on public utility buses.

In a 28-page decision penned by Justice Marvic M.V.F. Leonen, the Court En Banc ruled that petitioners Samson V. Pantaleon, et al. had “failed to present a clear factual foundation to rebut the presumption of validity of the challenged issuances” ― the MMDA’s Unified Vehicular Volume Reduction Program, otherwise known as the number coding scheme, embodied in MMDA Resolution No. 10-16 and MMDA Memorandum Circular No. 08, Series of 2010.

The Court held that the assailed MMDA issuances were validly issued pursuant to MMDA’s power to regulate traffic under RA 7924. Under RA 7924, the MMDA is vested with authority to regulate the delivery of metro-wide services in Metropolitan Manila. The said RA confers upon MMDA, through  the Metro Manila Council (MMC), the power to issue regulations that provide for a system to regulate traffic major thoroughfares of Metro Manila for the safety and convenience of the public.”

Furthermore, the Court held that the assailed MMDA issuances were issued within the limits of the powers granted to MMDA. It added that its discretion to reimpose the number coding scheme on public utility buses was a reasonably appropriate response to the serious traffic problem pervading Manila.

“The arbitrariness, oppressiveness and unreasonableness of the implementation of the issuances have not been sufficiently shown. The buses driven by petitioners have not been totally banned or prohibited from plying the Metro Manila roads. However, as in private vehicles, the operation of public utility buses in Metro Manila was merely regulated with a view to curb traffic congestion,” held the Court.

The Court stressed that “there is no outright deprivation of property but merely a restriction in the operation of public utility buses along the major roads of Metro Manla through the number coding scheme.”

Likewise, the Court held that the challenged issuances do no encroach upon the regulatory powers of the Land Transportation and Franchising Regulatory Board over public utility vehicles under EO 202. The MMDA issuances also are not violative of the due process clause of the Constitution.

The Court also held that petitioners, who are bus drivers plying along the routes between SM Fairview and Baclaran, are not the real parties in interest. The real parties in interest are the bus owners/operators or franchisees, it noted.

By virtue of a Memorandum of Agreement between MMDA and bus operators associations, public utility buses were partially exempted from the number coding scheme. However, the public utility buses were eventually included in the traffic scheme pursuant to the assailed MMDA issuances. This prompted the petitioners to raise the matter to the High Court. (G.R. No. 194335, Pantaleon v. MMDA, November 17, 2020)