Edu v.

Ericta
GR No. L-32096 – October 24, 1970
J. Fernando

Topic: Inherent Powers of the State – Police Power

Petitioners: Romeo F. Edu (Land Transportation Commissioner)

Respondents: Hon. Vicente G. Ericta (Judge CFI Rizal), Teddy C. Galo

DOCTRINE:

The Reflector Law is a valid exercise of police power because although it may be inefficient in
attaining the purpose, the test is not one of efficiency but only of logic. The rational basis test applies
in the case of police power versus property rights. Under the test, only a lawful purpose and a lawful
means must concur. In addition, the means used must have a reasonable relation to the end in view.

BACKGROUND OF THE CASE:

• The Supreme Court in this case for certiorari and prohibition rules on the constitutionality of the
Reflector Law
• Petitioner seeks to annul and set aside the order of Judge Ericta for the issuance of a
writ of preliminary injunction against A.O. No. 2 (implementing the Reflector Law)
• Respondent Teddy Galo assailed the validity of such enactment because it transgresses
the constitutional requirements of DUE PROCESS and NON-DELEGATION OF
POWER.

FACTS:

• May 20, 1970: Galo, on his behalf and that of other motorists filed a suit for certiorari and
prohibition with preliminary injunction assailing the validity of the Reflector Law.
• Galo argued that this was an invalid exercise of police power, and violative of the due
process clause.

• May 28, 1970: Galo manifested that in case that the Judge would rule that this is constitutional,
he sought that AO No. 2 be nullified as an undue exercise of legislative power.
• On the same day, Judge Ericta ordered issuance of a preliminary injunction directed
against the enforcement of AO No. 2

• A motion for reconsideration was filed by the SolGen representing petitioner Edu, and on June
4, 1970, Edu filed an answer which later on was still denied by Judge Ericta.

• June 30, 1970: Judge Ericta explained why he restrained the enforcement, and joined the SolGen
in seeking that the legal questions raised, namely the constitutionality of the Reflector Law and
validity of AO No. 2 be DEFINITELY DECIDED.
• With the foregoing petitions, answers, and oral arguments, the Court deems that this case is thus
ripe for decision.

ISSUES:

1. W/N it is proper for the Court to resolve the issue of the constitutionality of the Reflector
Law.
2. W/N the Reflector Law is constitutional and the Administrative Order No. 2
implementing it is valid

HELD:

1. YES - the main thrust of the petition before the court is to demonstrate in a convincing
fashion that the challenged legislation DOES NOT suffer from alleged constitutional
infirmities imputed by respondent Galo.

• There is already sufficient basis for the court to determine which view would prevail,
given that Galo already sought a declaration of nullity of such enactment (arguing that it is
violative of due process and deprivation of property rights)
• Further hearing by respondent Judge would be limited to a discussion of constitutional issues
raised.
• This is one case then where the question of validity is ripe for determination, no more time
should be further wasted.
• There is also a great public interest in the resolution of this case

2. YES, the court sustains the constitutionality of the Reflector Law as well as the validity of
AO No. 2.

First on the Constitutionality of the Reflector Law, as a valid exercise of Police Power

Reflector Law. Lights and reflector when parked or disabled - Appropriate parking lights or
flares visible one hundred meters away shall be displayed at a corner of the vehicle whenever
such vehicle is parked on highways or in places that are not well-lighted or is placed in such manner
as to endanger passing traffic. Furthermore, every motor vehicle shall be provided at all times
with built-in reflectors or other similar warning devices either pasted, painted or attached at its
front and back which shall likewise be visible at night at least one hundred meters away. No
vehicle not provided with any of the requirements mentioned in this subsection shall be registered.

• As seen from the law above, the challenged statute is a legislation enacted under the POLICE
POWER to promote public safety.

• Calalag v. Williams: Persons and property could thus be subjected to all kinds of restrains and
burdens in order to SECURE THE GENERAL COMFORT, HEALTH and PROSPERITY of
the state.
• Primicias v. Fugoso: there is the power to prescribe regulations to promote health, morals,
peace education, good orfer or safety and general welfare of the people
• Rubi v. Provincial Board: State has inherent and plenary power which enables it to prohibit all
things hurtful to comfort, safety, and welfare of society.
 DEFINING POLICE POWER: Court ruled therefore, that police power is a DYNAMIC
AGENCY, suitably vague and far from precisely defined, rooted in the conception that men in
organizing the state and imposing upon its government limitations to safeguard
constitutional rights, insuring communal peace, safety, good order, and welfare.

- Galo is of a different mind, having been timble to resist the teaching of many American
State Court decisions (American Jurisprudence)
- Unaccepting of the laissez faire postulate. As early as 1919, Justice Malcolm already said
that the doctrines of laissez-faire and of unrestricted individual freedom as axioms of
economic and political theory are of the past.
- Constitutional Convention also saw to it that the concept of laissez-faire was rejected.
The Constitution which took effect in 1935 is with a philosophy that is a repudiation of
laissez-faire.

Second on the Validity of A.O. No. 2, as a valid exercise of Police Power

 Although Congress may not delegate its legislative power to the two other branches of the
government, there are still exceptions.
- A standard must be set to avoid the taint of unlawful delegation
- What cannot be delegated is the authority under the constitution to make laws, alrer, and
repeal them.
-
 It must pass these two tests [Consti 1 lesson]:
- The COMPLETENESS TEST of the statute in all its terms and provision when it leaves
the hands of the legislators.
- It must also pass the SUFFICIENT STANDARD TEST, where there must be a standard
which implies at the very least that the legislature itself determines matters of principle
and lays down fundamental policy. (Also maps out boundaries, scope and limitations)

 There is a difference between delegation of power to determine what the law should be,
and delegation to fix the details in the execution of enforcement of a policy set out in the
law.
- The Reflector Law was construed together with the Land Transportation Code
- RA 4136 leaves no doubt as to the stress and emphasis on public safety
- This is its prime consideration, and it is under the power of petitioner as Land
Transportation Commissioner to promulgate riles and regulations to give life to and
translate into actuality such fundamental purpose.
- No abuse whatsoever.

RULING:

WHEREFORE, the writs of certiorari and prohibition prayed for are GRANTED.
 The previous orders of Judge Ericta issuing a writ of preliminary injunction on the Reflector
Law and AO No. 2 are ANNULED and SET ASIDE
 Judge Ericta also directed to DISMISS petition for certiorari and prohibition filed by Galo,
there being NO CAUSE OF ACTION to prove its invalidity.