Facts:
This case revolved around the constitutionality and validity of Ordinance No. 1664, enacted by the Sangguniang Panlungsod of the City of Cebu on January 27, 1997. The ordinance authorized traffic enforcers in Cebu City to immobilize vehicles violating parking restrictions by clamping their tires. Petitioners, who were vehicle owners affected by the enforcement of this ordinance, contested its validity on the grounds of due process violation. The Regional Trial Court (RTC) initially declared the ordinance unconstitutional, but the decision was reversed by the Court of Appeals (CA). Petitioners then elevated the matter to the Supreme Court.
The procedural journey began with the suits filed separately by Valentino Legaspi and the Jabans against the City of Cebu and several officials in RTC. Following the consolidation of the cases, the RTC ruled in favor of the petitioners, deeming Ordinance No. 1664 unconstitutional. The City of Cebu, as the respondent, appealed to the CA, which subsequently overturned the RTC’s ruling. The matter was then brought before the Supreme Court via petitions for review on certiorari, leading to the consolidation of these appeals.
Issues:
1. Whether Ordinance No. 1664 was within the legislative powers of the City of Cebu.
2. Whether the Ordinance complied with constitutional due process requirements, particularly in authorizing the immobilization of violating vehicles without prior hearing.
Court’s Decision:
The Supreme Court denied the petitions for review, affirming the CA’s decision, and upheld the constitutionality and validity of Ordinance No. 1664. The Court ruled that the ordinance was a legitimate exercise of the City of Cebu’s police powers, granted by the Local Government Code. It was enacted within the legislative capabilities of the LGU and passed in accordance with prescribed procedures. The Court also found that the ordinance met both the substantive and procedural due process requirements; it did not contravene the Constitution, was not unfair or oppressive, and served the public interest by addressing traffic congestion woes.
Doctrine:
The decision reiterated the doctrine that local government units (LGUs) have the authority, as delegated by the Local Government Code, to enact ordinances for the general welfare within their jurisdiction, inclusive of managing traffic flows and addressing illegal parking. It also underscored that an ordinance must adhere to both substantive and procedural due process standards — it must be enacted within the statutory and constitutional limits, aiming for public welfare without being arbitrary or oppressive.
Class Notes:
1. Police Power of LGUs: Local government units are empowered under the Local Government Code to enact ordinances essential for the promotion of the general welfare of their constituents, subject to constitutional and statutory limitations.
2. Due Process in Legislative Acts: Local ordinances, as legislative acts, must pass the tests of validity by not contravening the Constitution, not being unfair or oppressive, being general and consistent with public policies, and not unreasonable.
3. Delegation of Power: The authority of LGUs to regulate traffic and parking within their jurisdictions exemplifies the delegation of the State’s inherent powers, specifically police power, which is vested primarily in the legislature but can be delegated to local legislative bodies.
Historical Background:
The case presented a pivotal examination of the balance between the exercise of local autonomies, specifically the delegated police power to ensure public order and welfare, and the constitutional safeguards of due process. The enactment and enforcement of Ordinance No. 1664 by the City of Cebu epitomized a local government’s proactive measure against urban traffic congestion, situating the discourse within the broader narrative of advancing municipal governance while adhering to fundamental legal principles.
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