Primicias v. Municipality of Urdaneta
REITERATIONFacts
The Antecedents: On February 8, 1965, Juan Augusto B. Primicias was apprehended for allegedly violating Municipal Ordinance No. 3, Series of 1964, of Urdaneta, Pangasinan, for overtaking a truck near a school zone. Subsequently, a criminal complaint was filed against him. Procedural History: Primicias filed an action for the annulment of the ordinance and sought a preliminary injunction to restrain its enforcement. The Court of First Instance of Lingayen declared Ordinance No. 3, Series of 1964, null and void, made the preliminary injunction permanent, and ordered the return of Primicias' driver's license and payment of costs. The Petition: The defendants, the Municipality of Urdaneta, et al., appealed the decision of the Court of First Instance.
Issue(s)
Whether Municipal Ordinance No. 3, Series of 1964, is null and void. Whether the lower court erred in requiring the municipal council to give maximum allowable speed and classify highways. Whether the ordinance conflicts with Section 35 par. b(4) of Republic Act No. 4136. Whether the ordinance requires approval by the Land Transportation Commissioner. Whether the ordinance is clear and definite in its terms. Whether a writ of injunction was properly issued to restrain proceedings in the criminal case.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, declaring Municipal Ordinance No. 3, Series of 1964, null and void and making the writ of injunction permanent.
Ratio Decidendi
On the validity of Municipal Ordinance No. 3, Series of 1964: The Court held that the ordinance is null and void because it conflicts with Republic Act No. 4136, the Land Transportation and Traffic Code, which superseded Act No. 3992. The ordinance failed to comply with the mandatory requirements of Republic Act No. 4136, specifically Section 38, which mandates the classification of highways and the provision of appropriate signs, subject to the approval of the Land Transportation Commissioner. The ordinance also failed to make classifications of thoroughfares as required by Section 35(b) of Republic Act No. 4136, which specifies different speed limits for various types of roads and traffic conditions. By enacting an ordinance that did not conform to the "mother statute," the Municipal Council of Urdaneta exceeded its authority and contravened the law. On the requirement for classification of highways and maximum allowable speed: The Court affirmed the lower court's finding that the Municipal Council of Urdaneta failed to classify its thoroughfares as required by Section 38 of Republic Act No. 4136. This classification is necessary to implement the speed limits provided in Section 35(b) of the same Act, which distinguishes between different road types and traffic situations. The ordinance's failure to classify roads and its imposition of a uniform 20 kph limit on all national highways and provincial roads within Urdaneta, regardless of conditions, renders it invalid as it does not conform to the statutory scheme. On the conflict with Section 35 par. b(4) of Republic Act No. 4136: While Section 1(a) of the ordinance appears to restate part of Section 35(b)(4) of Republic Act No. 4136, it does so in isolation and without the necessary classifications mandated by the statute. The ordinance limits the speed to 20 kph in specific circumstances without considering whether the road is an open country road, a through street, or a city street with light traffic, as provided in the statute. This selective application and lack of comprehensive classification create a conflict with the statutory framework for speed limits. On the requirement for approval by the Land Transportation Commissioner: The Court found that the ordinance is invalid because there was no showing that the marking of streets and areas falling under Section 1(a) was done with the approval of the Land Transportation Commissioner, as required by Section 38 of Republic Act No. 4136. This approval is a crucial step in ensuring that local traffic regulations align with national standards and are properly implemented. On the clarity and definiteness of the ordinance's terms: The Court agreed with the lower court that the ordinance is not clear and definite because it used the term "vehicular traffic" without distinguishing between different types of vehicles, such as passenger cars and trucks/buses. This vagueness is problematic for a regulatory ordinance, as it fails to provide clear guidance to the average person regarding what conduct is prohibited and what penalties may be incurred. Republic Act No. 4136, in contrast, specifies speed limits for different types of vehicles. On the issuance of the writ of injunction: The Court held that the lower court did not err in issuing the writ of injunction to restrain the proceedings in the criminal case. While the general rule is that criminal prosecutions cannot be blocked by injunction, exceptions exist, including when the statute or ordinance relied upon is unconstitutional or invalid. Since Ordinance No. 3, Series of 1964, was found to be void, the exception applies. Furthermore, enjoining the enforcement of a void ordinance is sustained to prevent a multiplicity of prosecutions.
Main Doctrine
A municipal ordinance regulating traffic speed limits is invalid if it conflicts with the provisions of Republic Act No. 4136 (Land Transportation and Traffic Code), particularly regarding the classification of highways and the requirement for approval by the Land Transportation Commissioner. Furthermore, an injunction may be issued to restrain the enforcement of a void ordinance to prevent multiplicity of prosecutions.