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Updated 22nd March 2025
Edu vs. Ericta
The Supreme Court upheld the constitutionality of the Reflector Law and its implementing administrative order, ruling that the law was a valid exercise of police power to promote public safety and that the administrative order did not constitute an improper delegation of legislative power.

Primary Holding

The Reflector Law (RA 5715) and Administrative Order No. 2 are constitutional, as they reasonably advance public safety under the state’s police power and adhere to non-delegation principles.

Background

Respondent Teddy Galo challenged the Reflector Law and Administrative Order No. 2 (requiring vehicles to install reflectors) as violations of due process and non-delegation. The lower court issued a preliminary injunction against the order, prompting the petitioner to seek Supreme Court review.

History

  • May 20, 1970: Galo filed a petition for certiorari and prohibition in the CFI Rizal against the Reflector Law.

  • May 28, 1970: Respondent Judge Ericta ordered a preliminary injunction against Administrative Order No. 2.

  • June 4, 1970: Petitioner Edu filed his answer in the lower court.

  • June 9, 1970: Respondent Judge denied reconsideration of the injunction.

  • June 18, 1970: Edu filed a certiorari petition directly with the Supreme Court.

  • October 24, 1970: Supreme Court reversed the lower court’s injunction.

Facts

  • 1. The Reflector Law mandated reflectors on vehicles for visibility at night. Administrative Order No. 2 provided technical specifications for compliance. Galo argued the law and order infringed on property rights and delegated excessive legislative power.

Arguments of the Petitioners

  • 1. The Reflector Law is a valid exercise of police power to protect public safety.
  • 2. Administrative Order No. 2 was a lawful implementation under RA 4136 and did not improperly delegate legislative power.

Arguments of the Respondents

  • 1. The Reflector Law violated due process by imposing unreasonable costs on vehicle owners.
  • 2. Administrative Order No. 2 exceeded the authority granted by the statute, violating non-delegation principles.

Issues

  • 1. Whether the Reflector Law violates due process.
  • 2. Whether Administrative Order No. 2 constitutes an unconstitutional delegation of legislative power.

Ruling

  • 1. The Reflector Law is constitutional under the state’s police power to ensure road safety.
  • 2. Administrative Order No. 2 is valid as it adheres to the law’s standards and provides necessary implementation details.

Doctrines

  • 1. Police Power: The state may regulate property rights to protect public welfare.
  • 2. Non-Delegation Principle: Legislative power cannot be delegated, but executive agencies may fill in statutory details if guided by sufficient standards.

Key Excerpts

  • 1. “The Reflector Law is thus immune from the attack so recklessly hurled against it. It can survive, and quite easily too, the constitutional test.”
  • 2. “The laissez-faire doctrine is of the past. The modern period shows a belief in government activity to safeguard public welfare.”

Precedents Cited

  • 1. Calalang v. Williams (1940): Upheld traffic regulations under police power.
  • 2. Rubi v. Provincial Board (1919): Affirmed the state’s authority to regulate for public welfare.
  • 3. Climaco v. Macadaeg (1960): Supported judicial resolution of constitutional issues to serve public interest.

Statutory and Constitutional Provisions

  • 1. Calalang v. Williams (1940): Upheld traffic regulations under police power.
  • 2. Rubi v. Provincial Board (1919): Affirmed the state’s authority to regulate for public welfare.
  • 3. Climaco v. Macadaeg (1960): Supported judicial resolution of constitutional issues to serve public interest.