Edu v. Ericta

Case Title and Citation

Edu, in his capacity as Land Transportation Commissioner, petitioner, vs. Hon. Vicente G. Ericta, Judge of the Court of First Instance of Rizal, Quezon City, Branch XVIII, and Teddy C. Galo, respondents.
G.R. No. L-32096, October 24, 1970
Supreme Court - En Banc
Ponente: Justice Fernando

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Facts

• The Reflector Law, Republic Act No. 5715 (1969), amended Republic Act No. 4136 (1964) to require lighting and reflectors on motor vehicles to promote road safety.
• The statute provides that vehicles must be equipped with reflectors visible at 100 meters and prohibits registration of vehicles not meeting the requirements.
• Republic Act No. 5715 authorizes the Land Transportation Commissioner, with the Secretary of Public Works and Communications’ approval, to issue implementing regulations not conflicting with the Act.
• Administrative Order No. 2, issued April 17, 1970, implements the Reflector Law with detailed specifications on reflector types, placement, colors, and penalties for non-compliance.
• Teddy C. Galo, on May 20, 1970, filed a suit for certiorari and prohibition challenging the validity of the Reflector Law as an invalid exercise of police power.
• On May 28, 1970, he sought to enjoin Administrative Order No. 2 if the statute was constitutional; a hearing occurred on May 27, 1970; the Judge issued a preliminary injunction on May 28, 1970.
• A writ of preliminary injunction was issued on June 1, 1970, upon filing of bond; Edu answered on June 4, 1970; the Judge denied a motion for reconsideration on June 9, 1970.
• The petition for certiorari and prohibition was filed on June 18, 1970; the case was briefed and deemed ripe for decision, with the Court ultimately addressing the constitutional questions.

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Issues

1. Is the Reflector Law constitutional as a valid exercise of the police power?
2. Is Administrative Order No. 2 a valid exercise of executive/administrative power and not an invalid delegation of legislative authority?

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Ruling

1. Yes — The Reflector Law is constitutional as a valid exercise of the police power and does not violate due process.
2. Yes — Administrative Order No. 2 is a valid exercise of delegated authority, sufficiently guiding enforcement under the Reflector Law and not constituting an invalid delegation.

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Reasoning / Ratio Decidendi

• The Reflector Law is a public-safety measure enacted under the police power to promote safe transit on roads; it is not arbitrary or oppressive and withstands due process scrutiny.
• The decision traces the evolution of the police power from Calalang v. Williams through Primicias v. Fugoso, Rubi v. Prov. Board, and subsequent Philippine jurisprudence, noting the Constitution’s rejection of strict laissez-faire and its allowance for regulatory measures to promote general welfare.
• The Reflector Law, in combination with RA 4136 and its implementing framework, aims at public safety, a legitimate objective compatible with constitutional provisions.
• The challenge to Administrative Order No. 2 as an undue delegation is rejected because the statute provides a clear public-policy objective (public safety) and the regulation promulgated under it contains sufficient standards to guide implementation.
• Philippine precedents on delegated rulemaking (e.g., People v. Jolliffe, Yakus v. United States, Concepcion) support the view that agencies may promulgate detailed rules under a legislative directive, as long as standards sufficiently mark the field of enforcement and align with the statute’s objectives.
• The Court reaffirmed that the delegation is permissible when it concerns non-legislative, administrative details that implement a valid policy, with standards implied or express in the enabling statute.

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Doctrine / Legal Principle

• Police power as a dynamic, essential state function to promote public safety and general welfare.
• Rejection of laissez-faire as a governing principle; constitutional framework allows regulatory measures affecting property rights when justified by public safety and due process.
• Valid delegation allows administrative agencies to issue rules and regulations to implement a statute, provided standards sufficiently define the scope and purpose and the regulations are germane to the law’s objectives.
• Public safety and regulatory measures may withstand scrutiny if not arbitrary, oppressive, or capricious, and if they are reasonably related to the objectives of the law.

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Disposition

• The writs of certiorari and prohibition are granted.
• The May 28, 1970 order issuing a writ of preliminary injunction, the June 1, 1970 writ of preliminary injunction, and the June 9, 1970 denial of reconsideration are annulled and set aside.
• Respondent Judge Vicente G. Ericta is directed to dismiss Teddy C. Galo’s petition for certiorari and prohibition; there was no showing of invalidity in the Reflector Law or Administrative Order No. 2.
• Costs are not awarded.

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Concurring / Dissenting Opinions

• Concepcion, C.J. and Villamor, J. did not participate in the decision.

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Significance / Notes

• Endorses the constitutionality of safety-oriented regulatory schemes enacted under police power and their implementing regulations.
• Establishes that constitutional questions may be decided by the Supreme Court in certiorari/prohibition proceedings to avoid procedural delays and provide definitive guidance on important public-policy issues.
• Affirms the legitimacy of delegated regulatory detail when grounded in a statute with a clear public-safety objective and adequate standards to guide enforcement.
• Reinforces the jurisprudential shift away from laissez-faire toward a more affirmative government role in regulatory matters affecting public welfare.