CONSTITUTIONAL LAW
BAUTISTA VS. JUNIO
G.R. No L-50908 [January
31, 1984]
EN BANC, FERNANDO
C.J
Lawful Subject; Police
Power; LOI; No Violation of Equal Protection Clause
Police power refers to the capacity of
the states to regulate behavior and enforce order within their territory to
promote the health, safety, morals, and general welfare of their inhabitants.
The constitutionality of Letter of
Instruction (LOI) No. 869, a response to protracted oil crisis, banning the use
of private motor vehicles with H (heavy) and EH (extra heavy) plates on
week-ends and holidays, was assailed for being allegedly violative of the due
process and equal protection guarantees of the Constitution.
Petitioners also contends that
Memorandum Circular No. 39 issued by herein respondents imposing penalties of
fine, confiscation of the vehicle and cancellation of license of owners of the
above specified vehicles found violating such LOI, is likewise unconstitutional,
for being violative of the doctrine of “undue delegation of legislative power.”
Respondents denied the above
allegations.
Whether or not Letter of Instruction
869 as implemented by Memorandum Circular No. 39 is violative of certain
constitutional rights.
NO. The disputed regulatory measure is an appropriate
response to a problem that presses urgently for solution, wherein its
reasonableness is immediately apparent. Thus, due process is not ignored, much
less infringed. The exercise of police power may cut into the rights to liberty
and property for the promotion of the general welfare. Those adversely affected
may invoke the equal protection clause only if they can show a factual
foundation for its invalidity.
Moreover, since LOI No. 869 and MC No.
39 were adopted pursuant to the Land Transportation and Traffic Code which
contains a specific provision as to penalties, the imposition of a fine or the
suspension of registration under the conditions therein set forth is valid with
the exception of the impounding of a vehicle.
Important Legal
Principles
- Police Power:
- The case emphasizes the extent of
police power, which is the inherent authority of the state to enact laws
and regulations to promote public welfare, safety, and morals. The
decision recognized that local governments possess police power to
regulate land use and zoning.
- Due Process:
- The ruling also highlighted the
importance of due process in the exercise of police power. Even though
the government has broad authority, it must not infringe upon individual
rights without following appropriate legal procedures. The principles of
fairness and justice in regulatory actions were upheld.
- Lawful Subject:
- The Court discussed the necessity for
regulations enacted under police power to pertain to lawful subjects. The
regulations must be justified on legitimate grounds pertinent to public
health, safety, or morals and must also align with constitutional safeguards.
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