Carlos v. Reyes
REITERATIONFacts
The Antecedents: On December 5, 1935, at approximately 11:15 PM, police officer Glicerio Manzano observed an abandoned automobile (Star-Durant, motor No. 480585, chassis No. 1677, plate No. 31-745) parked on Franco Street. He placed a stone to mark its position and observed it remained unmoved until 6:00 AM the following day. He reported this to the Meisic police station. The defendant, police officer Catalino de los Reyes, arrived at approximately 7:10 AM to relieve Manzano. Sergeant Quevedo had previously warned De los Reyes about the abandoned vehicle. De los Reyes was instructed to wait until 7:30 AM and if the owner did not appear, to call the police station again. When the owner did not appear by 7:30 AM, De los Reyes was instructed to call the station again, and upon doing so, was told to deliver the vehicle to the City Pound if someone from the Pound arrived. The plaintiff appeared after the designated time, but De los Reyes, following orders, refused to release the vehicle to him and instead delivered it to the City Pound. Procedural History: The plaintiff filed a case in the Court of First Instance of Manila seeking the return of his automobile. The trial court rendered a judgment of acquittal, finding that the defendant did not appropriate or retain the vehicle for himself. The court concluded that the defendant acted in compliance with his duty under Manila City Ordinance No. 1684, as amended by Ordinances Nos. 1739 and 2313, because the vehicle was found abandoned on the street for more than eight hours. The court also noted that the plaintiff was informed of the vehicle's location and could reclaim it upon payment of the penalty, but he only complained to the Mayor without success. The Petition: The plaintiff appealed the decision, raising, among other factual issues, the validity of the ordinance.
Issue(s)
Whether Manila City Ordinance No. 1684, as amended, which declares vehicles parked on public streets for more than eight hours as abandoned and subject to impoundment, is valid. Whether Police Officer Catalino de los Reyes incurred civil or criminal liability for impounding the plaintiff's automobile.
Ruling
The Supreme Court affirmed the decision of the Court of First Instance, upholding the validity of the ordinance and absolving the defendant police officer of any liability.
Ratio Decidendi
On the validity of the ordinance: The Court held that the City of Manila possessed the power to enact Ordinance No. 1684, as amended, pursuant to Article 2444 of the Administrative Code. This article grants the Municipal Board the authority to prohibit the placing, depositing, or leaving of obstacles in streets and public places and to provide for their collection and disposition, as well as to abate nuisances. The Court reasoned that any obstruction impeding free passage on a public road constitutes a nuisance, and the ordinance was precisely enacted to prevent such obstructions. The exercise of police power by the City of Manila, delegated through its organic law, is broad enough to address public welfare and the needs of the community, including the removal of impediments on its streets, which are for public use. Leaving a vehicle on a public road for over eight hours without supervision is considered abandonment, justifying the actions of city agents. On the liability of the defendant police officer: The Court found that Police Officer Catalino de los Reyes acted in compliance with his duty and under the authority of the valid city ordinance. He was placed in a situation where he had to act according to his official responsibilities. The Court emphasized that when an individual acts in fulfillment of a duty and under superior orders for a lawful and permissible purpose, no criminal or civil liability is incurred. The defendant followed the instructions given by his superiors regarding the impoundment of the abandoned vehicle after the owner failed to appear within the stipulated time. Therefore, no responsibility could be attributed to him for the impoundment.
Main Doctrine
A police officer acting in compliance with a valid city ordinance to remove a vehicle obstructing public passage, after reasonable attempts to locate the owner, incurs no civil or criminal liability.