The Metro Manila Development Authority (MMDA) possesses the exclusive power to enforce traffic laws, rules and regulations in Metro Manila.

The Supreme Court aired this position in an en banc decision that also declared that local government units in Metro Manila may only enforce traffic laws if deputized by the MMDA.

The ruling penned by Associate Justice Alfredo Benjamin S. Caguioa granted the petition for review on certiorari filed by various transport organizations, public utility transport operators and drivers.

The decision reversed the Court of Appeals ruling that upheld the legality of traffic ordinances passed by Metro Manila LGUs.

Court records noted that local legislative councils of Manila Manila, Quezon City, Valenzuela City, Caloocan City, San Juan, Navotas, Las Piñas, Taguig, Pasay City, Muntinlupa City, Mandaluyong City, Makati City, Pasig City, and Pateros (respondent LGUs) passed ordinances providing traffic codes for their respective jurisdictions.

Among the ordinances passed provided authority for the LGU’s traffic enforcers to confiscate driver’s licenses and issue ordinance violation receipts (OVRs) to erring drivers.

The petitioners assailed the ordinances as violations of Republic Act No. 4136 or the law creating the Land Transportation Office and RA 7924 that created the MMDA.

The CA upheld the ordinances, ruling that there was no conflict between the MMDA Law and the Local Government Code (LGC), which grants LGUs the authority to enact ordinances.

The petitioners then appealed to the Supreme Court, seeking to enjoin the LGUs from implementing their OVR system and compel the MMDA to enforce the single ticketing system under the MMDA Law.

In its ruling, the SC stated that MMDA Law granted the MMDA all the rule-making powers related to traffic management in Metro Manila.

This included the authority to provide metro-wide services without infringing on the autonomy of LGUs.

One of the functions assigned to the MMDA was transport and traffic management, which encompassed the administration and implementation of all traffic enforcement operations, including the institution of a single ticketing system in Metro Manila.

The Court concluded that the MMDA Law's enactment indicated a clear legislative intent to make the MMDA the central policymaking body in Metro Manila regarding traffic management.

Therefore, the MMDA had the power to set policies and coordinate and regulate the implementation of all traffic management programs and projects in Metro Manila.

Despite the LGC granting LGUs the power to regulate traffic, this power did not apply to cities and the lone municipality in Metro Manila due to the MMDA Law's primacy.

The Court ruled that the MMDA Law's Sections 5(e) and 5(f) took precedence over the relevant sections of the LGC, empowering the MMDA to regulate traffic in Metro Manila.

While LGUs possess delegated legislative powers, they must act in conformity with the will of their principal, the State.

The Court further clarified that the power of the LGUs to regulate the streets is valid only “insofar as they pertain to ‘purely local matters’ such as, but are not limited to, determination of one-way streets, regulation of alleys and inner streets, prohibiting the putting up of encroachments and obstacles, and authorizing the removal of such encroachments, etc.

And even as that power continues to inhere in the LGUs, that power is circumscribed and limited by the regulations that may be issued by the MMDA.”