### Facts:
Leovillo C. Agustin, herein petitioner, challenges the mandate necessitating motor vehicles to be equipped with early warning devices (EWDs) through Letter of Instruction No. 229 issued by then-President Marcos on December 2, 1974, its amendment by Letter of Instruction No. 479, and its implementing rules issued by respondent Romeo F. Edu, Land Transportation Commissioner. Agustin, owning a properly equipped Volkswagen Beetle argued that the Letter of Instruction and the implementing rules violated constitutional guarantees of due process, by being arbitrary and oppressive. Moreover, he claimed it constituted an unlawful delegation of legislative power.
The respondent officials, represented by Solicitor General Estelito P. Mendoza, contended that the Letter of Instruction was a valid exercise of police power aimed at promoting public safety and that its implementing rules did not amount to unlawful legislative delegation. The case escalated to the Supreme Court after a temporary restraining order was issued against the enforcement of said provisions, pending resolution.
### Issues:
1. Whether the Letter of Instruction No. 229 and its subsequent amendments, mandating the possession and use of EWDs by motor vehicle owners, violate the constitutional guarantee of due process.
2. Whether the implementing rules and regulations issued under Letter of Instruction No. 229 constitute an unlawful delegation of legislative power.
### Court’s Decision:
The Supreme Court dismissed the petition, upholding the validity of the Letter of Instruction No. 229 and its amendments as well as the implementing rules and regulations issued by the Land Transportation Commissioner.
1. On the issue of due process, the Court ruled that the Letter of Instructions was a valid exercise of police power, aimed at ensuring public safety by reducing traffic accidents caused by stalled or disabled vehicles. The Court emphasized the broad scope of police power to promote the general welfare and noted the factual basis for the challenged provisions, which were supported by international norms and the Vienna Convention on Road Traffic, to which the Philippines is a signatory.
2. Regarding the alleged unlawful delegation of legislative power, the Court found that sufficient standards were established in the Letter of Instruction itself, which guided the implementation by the administrative agency. The Court underscored that legislation may entrust regulatory agencies with the authority to implement laws, provided that a standard exists to guide their actions.
### Doctrine:
The ruling reinforced the doctrine that police power is a dynamic and expansive authority of the state to regulate for the public welfare. It clarified that the delegation of legislative power is permissible when a clear standard is set by the law to guide the implementing body.
### Class Notes:
– **Police Power**: The state’s inherent authority to regulate towards promoting the general welfare, health, and safety of the public.
– **Due Process**: A constitutional guarantee that laws will not be arbitrary, oppressive, or unreasonable, ensuring fairness in legal proceedings and governmental actions.
– **Non-Delegation of Legislative Power**: The principle that legislative bodies cannot delegate their law-making powers to other entities unless they provide clear standards guiding the exercise of such delegated powers.
– **Early Warning Devices (EWDs)**: Safety equipment mandated to be carried in motor vehicles to signal to approaching motorists the presence of stalled or disabled vehicles.
### Historical Background:
The case manifests the Marcos administration’s approach to public safety and vehicular regulation during the Martial Law period in the Philippines. It demonstrates the government’s intent to align with international standards—specifically, the 1968 Vienna Convention on Road Signs and Signals—and highlights the tension between executive directives and constitutional safeguards during this era.
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