KAPIT vs. City of Manila

The existence of an actual case or controversy is an absolute and indispensable prerequisite of judicial review; a case rendered moot by supervening events may be dismissed notwithstanding public interest unless a recognized exception applies, and none applied where the challenged NCAP City Ordinances had been functionally abrogated by the MMTC 2023 and adopting ordinances. Threshold procedural defects—lack of standing, non-exhaustion of administrative remedies, violation of the hierarchy of courts, and forum shopping—warrant dismissal without reaching the merits.

The MMDA sought to establish a technology-driven, no-contact traffic enforcement system to shift from immediate physical apprehension to post-violation notification and adjudication. The Metro Manila Council issued resolutions, including MMDA Resolution No. 16-01, adopting a No Physical Contact Policy through digital cameras and similar technologies. Respondent LGUs subsequently promulgated and implemented NCAP City Ordinances. The regulatory backdrop included Republic Act No. 4136, the Local Government Code, and the MMDA charter.

The MMDA sought to establish a technology-driven, no-contact traffic enforcement system to shift from immediate physical apprehension to post-violation notification and adjudication. To this end, the Metro Manila Council issued resolutions, including MMDA Resolution No. 16-01, adopting and implementing a No Physical Contact Policy for apprehension of traffic violators through digital cameras. The policy aimed to reduce traffic congestion and curb opportunities for corruption. The MMC later authorized the use of CCTV cameras, digital imaging, and similar technologies to detect and document traffic violations along major roads in Metro Manila, and prescribed procedures for camera-based apprehension, including issuance of notices of violation, payment of fines, and the right of violators to contest the citation before the Traffic Adjudication Board or the MMDA Traffic Adjudication Division.

Respondent LGUs subsequently promulgated and implemented the assailed NCAP City Ordinances. These ordinances authorized the installation of traffic enforcement cameras, the creation of a Motor Vehicle Registration Alert System, linkage with the LTO database, the sending of notices of violation to registered owners, protest mechanisms before local traffic adjudication bodies, trust funds, and honoraria. Several LGUs entered into joint venture agreements with QPAX Traffic Systems Incorporated for the necessary technology and infrastructure.

Atty. Paa alleged that he only discovered his four traffic violations in 2021 when he was refused registration of his motor vehicle in 2022. The total fines with penalties reached PHP 20,360.00. He observed that his address in the notices was incorrect, demonstrating how the NCAP system is error-prone, burdensome, and prejudicial to registered owners who may not be the actual drivers who committed the traffic violation. KAPIT et al. asserted interest in the case as representatives of their members who are public utility transport operators and drivers duly authorized by the LTFRB. PNTOA et al. declared that they previously filed a petition against the Manila Traffic and Parking Bureau and the Manila Traffic Adjudication Board before Branch 16, RTC Manila, assailing the city's NCAP implementation.

Thereafter, the MMDA and LTO manifested that the Metro Manila Council adopted and approved the Single Ticketing System through MMDA Resolution No. 23-02, series of 2023, and the Metro Manila Traffic Code of 2023. The MMTC 2023 provided a common definition of traffic violations, a Unified Ordinance Violation Receipt, a uniform traffic adjudication system, guidelines on Data Privacy Act compliance, uniform fines, online payment platforms, and authorization processes for IT systems. Respondent LGUs enacted ordinances adopting the MMTC 2023. The challenged NCAP City Ordinances were thus functionally abrogated, and respondent LGUs subordinated their traffic regulations to the uniform standards prescribed by the MMDA.

• KAPIT et al. — RA 4136 and Face-to-Face Apprehension: KAPIT et al. alleged that the NCAP is contrary to Sections 29 and 62 of Republic Act No. 4136, which contemplates face-to-face apprehension and imposes liability on the erring driver, not registered owners.
• KAPIT et al. — Due Process: They claimed that the NCAP violates due process because motorists are imposed penalties without immediate notice or opportunity to contest the violation at the time of recording, and face accumulated fines without prior notice.
• KAPIT et al. — Privacy and Data Protection: They contended that the NCAP disregards privacy and data protection rights, as there are inadequate safeguards for the collection and use of personal and vehicle data.
• KAPIT et al. — Registered Owner Rule: They argued that the presumptive violator is automatically the registered vehicle owner, regardless of the actual driver.
• Atty. Paa — Due Process, Privacy, and Excessive Fines: Atty. Paa averred that the City of Manila's NCAP ordinance violates his fundamental rights to due process and privacy, as well as his right against excessive fines and penalties. He alleged that he only discovered his four traffic violations in 2021 when he was refused registration of his motor vehicle in 2022, and that the total fines with penalties reached PHP 20,360.00. He observed that his address in the notices was incorrect.
• PNTOA et al. — Due Process and RA 4136: PNTOA et al. argued that the NCAP City Ordinances are unconstitutional for violating the fundamental tenets of due process and Republic Act No. 4136.
• PNTOA et al. — Jurisdiction: They posited that granting exclusive jurisdiction to hear and decide NCAP-related traffic violations to respondent LGUs' respective traffic adjudication boards contravenes both Batas Pambansa Blg. 129 and Article VIII, Sections 1 and 2 of the Constitution.
• Forum Shopping: KAPIT et al. and PNTOA et al. denied committing forum shopping. KAPIT argued that the RTC Makati case assailed the MMDA NCAP, not the city ordinances; PNTOA et al. argued that there was no identity of parties and relief sought.
• Standing and Direct Resort: KAPIT et al. claimed legal capacity to sue as corporate entities and as representatives of stakeholders, private operators, motorists, and the general public. Atty. Paa justified direct filing with the Court by claiming transcendental importance.

• Procedural Defects: Respondent LGUs moved for dismissal on procedural and substantive grounds. They cited failure to establish all the requirements for judicial review, specifically actual case or controversy and standing. They also contended that the petitions violate the doctrine of hierarchy of courts. The City of Manila alleged forum shopping against PASANG MASDA and ACTO, and failure to exhaust administrative remedies against Atty. Paa. Quezon City added improper recourse as a ground, stating that the Court is not a trier of facts.
• Police Power: Respondent LGUs argued that the NCAP is a valid exercise of police power and a valid exercise of delegated police power under the Local Government Code. They submitted that the NCAP promotes traffic discipline, efficient road use, and public safety.
• MMDA Authority: The MMDA reasoned that the NCAP is a valid exercise of its traffic management and regulatory authority, supported by its charter and relevant laws, and implemented in coordination with LGUs. It stated that the use of technology enhances enforcement and minimizes corruption and traffic disruption.
• Due Process: Respondent LGUs countered that there is no violation of due process since registered owners are given the opportunity to contest the notice of violation and imposition of penalties before the appropriate adjudicatory body.
• RA 4136: Respondent LGUs and the MMDA asserted that the NCAP does not violate Republic Act No. 4136, as the law does not limit apprehension of traffic violators to face-to-face apprehension.
• Presumption of Constitutionality: The City of Manila and Quezon City remarked that the NCAP City Ordinances enjoy the presumption of constitutionality, which petitioners failed to overcome.
• Atty. Paa: The City of Manila posited that submission of correct information is the duty of the registered owner and is not the burden of the local government.
• Privacy: The MMDA argued that the MMDA NCAP and the NCAP City Ordinances do not violate a motorist's right to privacy.
• QPAX: QPAX maintained that its role is limited to providing the infrastructure for traffic enforcement. The authority to apprehend, adjudicate, and penalize violators remains with government agencies and LGUs. It further contended that the use of its automated detection systems reliably enhances traffic enforcement, and the NCAP framework has safeguards that ensure due process and accuracy.
• LTO: The LTO emphasized that it does not have privity of contract with QPAX. It added that the information necessary to carry out the functions of public authorities lies outside the scope of the Data Privacy Act of 2012.

• Actual and Justiciable Controversy: Whether the issues raised in the Petitions involve an actual and justiciable controversy.
• Legal Capacity to Sue: Whether petitioners have legal capacity to sue.
• Locus Standi: Whether petitioners each have locus standi.
• Direct Resort to the Supreme Court: Whether petitioners' direct resort to the Supreme Court is proper.
• Forum Shopping: Whether petitioner KAPIT committed forum shopping in violation of Rule 7, Section 5 of the 2019 Amendments to the 1997 Rules of Civil Procedure.
• Police Power: Whether the implementation of the NCAP is a valid exercise of police power.
• Privacy: Whether the NCAP City Ordinances violate the constitutional right to privacy.
• Excessive Fines: Whether the NCAP City Ordinances violate the constitutional right against excessive fines and penalties.
• Local Autonomy: Whether the implementation of the NCAP City Ordinances is a valid exercise of local autonomy.
• RA 4136: Whether the NCAP City Ordinances violate the provisions of Republic Act No. 4136.
• Registration Renewal Condition: Whether the payment of penalties for violations of the NCAP City Ordinances can be made a condition for the renewal of motor vehicle registration under Republic Act No. 4136.
• Prescriptive Period: Whether the condition of payment of penalties before renewal of motor vehicle registrations violates the two-month prescriptive period for the violation of municipal ordinances under Act No. 3326.
• Data Privacy Act: Whether the NCAP City Ordinances can be declared unconstitutional if the Court finds that their implementation violated specific provisions of the Data Privacy Act of 2012.
• Operative Fact Doctrine: Whether the operative fact doctrine shall apply if the NCAP is declared unconstitutional.
• Usurpation of Legislative Authority: Whether the NCAP City Ordinances constitute a usurpation of legislative authority for expanding the coverage of traffic regulations under Republic Act No. 4136.

• Actual and Justiciable Controversy: No. Supervening events rendered the Petitions moot, and none of the recognized exceptions to the mootness doctrine applied.
• Legal Capacity to Sue: No as to PASANG MASDA and ACTO, which lack legal capacity as unregistered associations. KAPIT and ALTODAP failed to establish third-party standing. Atty. Paa has standing.
• Locus Standi: No for KAPIT et al., who failed to show personal and direct injury. Yes for Atty. Paa, who alleged direct injury from the enforcement of the Manila NCAP Ordinance.
• Direct Resort to the Supreme Court: No as to Atty. Paa. He failed to exhaust administrative remedies and violated the hierarchy of courts; his petition did not raise purely questions of law.
• Forum Shopping: KAPIT did not commit forum shopping. PNTOA et al. are guilty of forum shopping.
• Police Power: Not reached. The Court dismissed the Petitions on threshold grounds without ruling on the merits.
• Privacy: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Excessive Fines: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Local Autonomy: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• RA 4136: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Registration Renewal Condition: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Prescriptive Period: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Data Privacy Act: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Operative Fact Doctrine: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Usurpation of Legislative Authority: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.

• Actual and Justiciable Controversy: The Court held that the existence of an actual case or controversy is an absolute and indispensable prerequisite of judicial review. The challenged NCAP City Ordinances were superseded by ordinances adopting the MMTC 2023, and respondent LGUs subordinated their traffic regulations to the uniform standards prescribed by the MMDA. The challenged ordinances were rendered functus officio and functionally abrogated. Any declaration of their unconstitutionality or infirmity would produce neither legal nor practical effect. The Court found that none of the exceptions to mootness applied: there was no ongoing or threatened constitutional injury attributable to the challenged ordinances; public interest alone cannot confer jurisdiction; existing jurisprudence on privacy, due process, and excessive fines is well-developed; and the capable-of-repetition-yet-evading-review exception was speculative because the new legal scheme involves different parameters and safeguards. The dismissal was without prejudice to future challenges should the modified implementation give rise to an actual justiciable case.
• Legal Capacity to Sue: PASANG MASDA and ACTO lack legal capacity to sue because they are not registered with the Securities and Exchange Commission. KAPIT and ALTODAP lack third-party standing because they failed to identify their members and demonstrate that they were allowed by said members to sue on their behalf. Their belated claim that they are filing for stakeholders, private operators, motorists, and the general public did not save their failure to establish third-party standing. Atty. Paa, however, could be considered to have sustained a personal and direct injury or be at risk of sustaining direct injury from the implementation of the assailed City of Manila NCAP Ordinance, considering his allegation that he was constrained to pay fines with penalties as a condition precedent for the registration of his vehicle for 2022-2023 without being furnished with notices of violation.
• Locus Standi: The Court defined locus standi as a personal and substantial interest in a case such that the party has sustained or will sustain direct injury as a result of the governmental act being challenged. Atty. Paa satisfied this requirement because he alleged direct injury from the enforcement of the Manila NCAP Ordinance. KAPIT et al. failed to show personal and direct injury arising from the implementation of the NCAP City Ordinances. Their representative interest was insufficient, and they failed to establish third-party standing.
• Direct Resort to the Supreme Court: Atty. Paa did not exhaust his administrative remedies. He paid PHP 20,360.00 in penalties to facilitate the registration of his vehicle after failing to obtain a waiver of the penalties. Rather than contest his purported violation and penalties before the proper adjudication board, he went directly before the Court. None of the exceptions to exhaustion was proven applicable. He also did not provide sufficient justification for bypassing the Regional Trial Court or the Court of Appeals, which exercise concurrent jurisdiction over petitions for certiorari, prohibition, and mandamus. His Petition did not raise purely questions of law; there were factual bases that must be established before the Court could definitively rule on the legal questions. The Court is not a trier of facts.
• Forum Shopping: KAPIT did not commit forum shopping. The RTC Makati case questioned the MMDA's authority to issue the MMDA NCAP and the MMC's authority to approve it, and assailed the MMDA NCAP. The assailed issuances in KAPIT's petition are the NCAP City Ordinances issued by respondent LGUs, not the MMDA NCAP. There was no identity of parties and no identity of issues. PNTOA et al., however, are guilty of forum shopping. The RTC Manila case and the present Petition have identity of interest between the parties, identity of issues, and identity of relief. The RTC Manila case challenged Section 3, Paragraph 4 of Ordinance No. 8676, the authority of respondents to hear and decide traffic violations, and the application of the registered owner rule. The difference between the City of Manila and the Manila Traffic and Parking Bureau and Manila Traffic Adjudication Board is merely nominal. Mere disclosure of the pendency of the RTC Manila case does not preclude a finding of forum shopping. A finding of forum shopping results in summary dismissal of both the Petition before the Court and the related lower court case.
• Police Power: Not reached. The Court dismissed the Petitions on threshold grounds and expressly stated that the dismissal should not be taken to mean that the challenged framework is valid. The dismissal was confined to the determination that petitioners failed to overcome threshold issues and that the supervening adoption of a uniform regulatory framework rendered the Petitions moot.
• Privacy: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Excessive Fines: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Local Autonomy: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• RA 4136: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Registration Renewal Condition: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Prescriptive Period: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Data Privacy Act: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Operative Fact Doctrine: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.
• Usurpation of Legislative Authority: Not reached. The Court made no ruling on the constitutionality of the assailed issuances.

• Actual Case or Controversy — The existence of an actual case or controversy is an absolute and indispensable prerequisite of judicial review. It must be established through the petitioner's allegations, evaluated against the requirements of standing and ripeness. The Court cannot act when its jurisdiction has not been properly invoked.
• Mootness and Exceptions — A case or issue is moot and academic when it ceases to present a justiciable controversy by virtue of supervening events, so that an adjudication would be of no practical value or use. The recognized exceptions are: (a) grave violation of the Constitution; (b) exceptional character of the situation and paramount public interest; (c) constitutional issue requires formulation of controlling principles to guide the bench, the bar, and the public; and (d) case is capable of repetition yet evading review. None applied in this case.
• Public Interest Alone Does Not Confer Jurisdiction — Public interest is not sufficient to justify continued judicial action where the legal landscape has fundamentally shifted. The exceptional character and paramount public interest exception applies only when the case involves interests of the general public, as distinguished from those of a particular class. In this case, the issues involved a particular class of public, i.e., motorists.
• Need to Formulate Controlling Principles — Deviation from the mootness principle under this exception demands a showing that existing jurisprudence on the constitutional or legal issues presented is conceptually inadequate, not merely as applied in a given case, but fundamentally insufficient as a matter of doctrine. The constitutional rights to privacy, due process, and protection against excessive fines are not unexplored terrain.
• Capable of Repetition Yet Evading Review — This exception requires a showing of reasonable expectation or demonstrated probability that the same controversy will recur between the same or similarly situated parties. A mere prediction or supposition that related constitutional questions might eventually be raised by anyone, anywhere, in some future proceeding would not suffice.
• Legal Standing/Locus Standi — Legal standing is a personal and substantial interest in a case such that the party has sustained or will sustain direct injury as a result of the governmental act being challenged. The gist is whether a party alleges such personal stake in the outcome of the controversy as to assure concrete adverseness.
• Third-Party Standing — Actions may be brought on behalf of third parties provided: first, the party bringing suit must have suffered an injury-in-fact; second, the party must have a close relation to the third party; and third, there must exist some hindrance to the third party's ability to protect their own interests.
• Unincorporated Associations Lack Capacity to Sue — An unincorporated association, in the absence of an enabling law, has no juridical personality and cannot sue in the name of the association. All members of the association must be made parties in the civil action.
• Exhaustion of Administrative Remedies — Before one is allowed to seek intervention of the courts, one must first avail of all administrative processes as a necessary precondition. The doctrine is subject to exceptions, including where the question involved is purely legal and will ultimately have to be decided by the courts of justice, where judicial intervention is urgent, and where the controverted acts violate due process.
• Hierarchy of Courts — Although the Supreme Court, the Court of Appeals, and the Regional Trial Courts have concurrent original jurisdiction over petitions for certiorari, prohibition, mandamus, quo warranto, and habeas corpus, parties are directed, as a rule, to file their petitions before the lower-ranked court. Failure to comply is sufficient cause for dismissal. To invoke exceptions, petitioners must purely raise questions of law.
• Forum Shopping — Forum shopping is committed when a party avails of several judicial remedies in courts, simultaneously or successively, all substantially founded on the same transactions and the same essential facts and circumstances, and all raising substantially the same issues either pending in or already resolved adversely by some other court. The elements are: (a) identity of parties or at least such parties that represent the same interests in both actions; (b) identity of rights asserted and reliefs prayed for, the relief founded on the same facts; and (c) any judgment rendered in one action will amount to res judicata in the other action.
• Disclosure vs. Commission of Forum Shopping — Compliance with the certification against forum shopping is separate from and independent of the avoidance of the act of forum shopping itself. Mere disclosure of the pendency of a related case does not preclude a finding of forum shopping.
• Twin Dismissal for Forum Shopping — A finding of forum shopping results in summary dismissal of both the Petition before the Supreme Court and the related lower court case. This twin dismissal serves to uphold the proper administration of justice.
• Presumption of Validity and Constitutionality — Laws and ordinances enjoy the presumption of validity and constitutionality. Anyone who assails their validity bears the burden of clearly and convincingly showing infirmity. Courts will not declare a law or ordinance unconstitutional unless there is a clear and unequivocal breach of the Constitution.
• End Does Not Justify the Means — In a democracy, the end does not justify the means. No objective, no matter how laudable, justifies transgression of fundamental human rights. The pursuit of advancement must always be tempered by respect for basic human liberties and the rule of law.
• Dismissal Without Prejudice — The dismissal of the Petitions was without prejudice to the invocation of the substantive and constitutional questions in a petition that adequately satisfies the requisites of judicial review, and to future challenges should the modified implementation give rise to an actual justiciable case.

• "The existence of such a case or controversy is not presumed. It must be established through the petitioner's allegations, evaluated against Our basic procedural requisites as shaped by the requirements of standing (of the petitioners to lodge the case) and ripeness (of the controversy for adjudication)." — This passage states the threshold requirement of an actual case or controversy and ties it to standing and ripeness.
• "Here, supervening circumstances have since arisen that materially transformed the regulatory milieu at the heart of these consolidated Petitions. The legal and factual terrains upon which the challenged NCAP City Ordinances once operated have been substantially altered, such that the scope and efficacy of said Ordinances can no longer be assessed within the framework originally presented by the petitioners. The issues tendered for this Court's resolution have been overtaken by such events, rendering them effectively moot and beyond the necessity of judicial determination." — This is the core mootness ruling of the majority.
• "To engage in a resolution of the constitutional and legal challenges leveled against the assailed NCAP City Ordinances would be, at this juncture, a patently futile judicial exercise. Those Ordinances have been rendered functus officio by the subsequent enactments of the concerned LGUs, all of which have been calibrated in conformity with the MMTC 2023, which is not being challenged in these petitions or in any other forum." — This passage explains why the Court declined to reach the merits and why any ruling would be illusory.
• "A finding of forum shopping results in summary dismissal of both the Petition before this Court and the related lower court case. This twin dismissal serves to uphold the proper administration of justice." — This states the consequence of the finding that PNTOA et al. committed forum shopping.

• David vs. Macapagal-Arroyo, 522 Phil. 705 (2006) — Cited for the recognized exceptions to the mootness principle: grave violation of the Constitution, exceptional character and paramount public interest, need to formulate controlling principles, and capable of repetition yet evading review.
• Peñafrancia Sugar Mill, Inc. vs. Sugar Regulatory Administration, 728 Phil. 535 (2014) — Cited for the definition of a moot and academic case: it ceases to present a justiciable controversy by virtue of supervening events, so that adjudication would be of no practical value or use.
• Abakada Guro Partylist, Inc. vs. Purisima, 584 Phil. 246 (2008) — Cited for the rule that a constitutional question is ripe for adjudication when the governmental act being challenged has a direct and existing adverse effect on the individual challenging it.
• Galicto vs. President Aquino III, 683 Phil. 141 (2012) — Cited for the definition of locus standi or legal standing as a personal and substantial interest in a case such that the party has sustained or will sustain direct injury as a result of the governmental act being challenged.
• Provincial Bus Operators Association of the Philippines vs. Department of Labor and Employment, 836 Phil. 205 (2018) — Cited for the rule that associations failed to establish who their members are and if these members allowed them to sue on their behalf; without such proof, they lack standing.
• Samar II Electric Cooperative, Inc. vs. Seludo, Jr., 686 Phil. 786 (2012) — Cited for the doctrine of exhaustion of administrative remedies and its exceptions.
• Gios-Samar, Inc. vs. Department of Transportation and Communications, 849 Phil. 120 (2019) — Cited for the doctrine of hierarchy of courts and the rule that direct recourse to the Supreme Court is allowed only when the questions raised are purely legal.
• Asia United Bank vs. Goodland, Co., Inc., 660 Phil. 504 (2011) — Cited for the definition of forum shopping.
• Pentacapital Investment Corporation vs. Mahinay, 637 Phil. 283 (2010) — Cited for the three ways of committing forum shopping: litis pendentia, res judicata, and splitting of causes of action.
• Republic vs. Sandiganbayan, 947 Phil. 157 (2023) — Cited for the elements of forum shopping.
• Spouses Ong vs. Court of Appeals, 433 Phil. 490 (2002) — Cited for the distinction between the prohibition against forum shopping and the certification requirement, and for the rule that mere disclosure does not preclude a finding of forum shopping.
• Montes vs. Court of Appeals (Sixth Division), 523 Phil. 98 (2006) — Cited for the rule that filing a special civil action before the Supreme Court during the pendency of a motion for reconsideration involving the same relief constitutes forum shopping.
• Cruz vs. Court of Appeals, 517 Phil. 572 (2006) — Cited for the rule that only substantial identity of parties is required for res judicata; the addition or elimination of some parties does not alter the situation.
• Buan vs. Lopez, 229 Phil. 65 (1986) — Cited for the rule that a finding of forum shopping results in summary dismissal of both the petition before the Supreme Court and the related lower court case.
• Chavez vs. Public Estates Authority, 433 Phil. 506 (2002) — Cited for the rule that the grave violation of the Constitution exception to mootness is animated by the Court's duty to prevent ongoing or threatened constitutional injury, not to issue retrospective declarations on ordinances already removed from the legal order.
• Ople vs. Torres, 354 Phil. 948 (1998) — Cited to show that the right to privacy and the need for adequate safeguards in systems collecting personal details are well-developed in jurisprudence.
• Ang Tibay vs. Court of Industrial Relations, 69 Phil. 635 (1940) — Cited to show that case law on substantial and procedural due process is well-developed and readily applicable.
• Republic vs. N. Dela Merced & Sons, Inc., 824 Phil. 87 (2018) — Cited to show that the constitutional proscription on excessive fines applies only to criminal prosecutions and that the principles governing it are well-entrenched.
• Atty. Macalintal vs. Commission on Elections, 943 Phil. 212 (2023) — Cited for the concepts of judicial power and the requirement of an actual case or controversy.
• Francisco, Jr. vs. House of Representatives, 460 Phil. 830 (2003) — Cited for the expanded scope of judicial power to determine grave abuse of discretion.
• Madrilejos vs. Gatdula, 863 Phil. 754 (2019) — Cited for the requirement of reasonable expectation or demonstrated probability that the same controversy will recur for the capable-of-repetition-yet-evading-review exception to apply.

• Article VIII, Section 1, 1987 Constitution — Provides that judicial power includes the duty to settle actual controversies involving legally demandable and enforceable rights and to determine grave abuse of discretion. The Court applied this provision in holding that an actual case or controversy is an absolute prerequisite of judicial review.
• Article III, Section 1, 1987 Constitution — Guarantees due process and equal protection. The Court noted that the due process issues raised by petitioners were not unexplored terrain and that existing jurisprudence was well-developed, which supported the finding that the need-to-formulate-controlling-principles exception to mootness did not apply.
• Article III, Section 19(1), 1987 Constitution — Prohibits excessive fines and cruel, degrading, or inhuman punishment. The Court noted that the constitutional provision on excessive fines is self-executing and that the principles governing it are well-entrenched in jurisprudence, which supported the finding that no significant doctrinal gap warranted intervention in a moot case.
• Rule 7, Section 5, 2019 Amendments to the 1997 Rules of Civil Procedure — Requires a certification against forum shopping. The Court applied this provision in finding that PNTOA et al. committed forum shopping, and that mere disclosure of the pendency of the RTC Manila case did not preclude such a finding.
• Republic Act No. 4136, Sections 29 and 62 — Cited by petitioners as the basis for their argument that the NCAP is contrary to the Land Transportation and Traffic Code because it contemplates face-to-face apprehension and imposes liability on the erring driver. The Court did not rule on the merits of this argument because it dismissed the Petitions on threshold grounds.
• Act No. 3326 — Cited in the issue on whether the condition of payment of penalties before renewal of motor vehicle registration violates the two-month prescriptive period for violations of municipal ordinances. The Court did not rule on the merits of this issue.
• Republic Act No. 10173 (Data Privacy Act of 2012) — Cited in the issue on whether the NCAP City Ordinances can be declared unconstitutional if their implementation violated specific provisions of the Data Privacy Act. The Court did not rule on the merits of this issue.
• Republic Act No. 7160 (Local Government Code), Sections 447 and 458 — Cited in the issue on whether the implementation of the NCAP City Ordinances is a valid exercise of local autonomy. The Court did not rule on the merits of this issue.
• Batas Pambansa Blg. 129 — Cited in the issue on whether granting exclusive jurisdiction to LGU traffic adjudication boards contravenes the Judiciary Reorganization Act. The Court did not rule on the merits of this issue.
• MMDA Resolution No. 16-01; Metro Manila Traffic Code of 2023; MMDA Memorandum Circular No. 10, series of 2025 — These issuances were the supervening events that rendered the challenged NCAP City Ordinances functus officio and functionally abrogated. The Court relied on them in holding that the Petitions had become moot.

Gesmundo, C.J., Caguioa, Inting, Marquez, Singh, and Villanueva, JJ., concur. Hernando, J., was on official business but left a vote. Lazaro-Javier, J., concurred only as to result and maintained that a discussion on the validity of the NCAP ordinances was proper; she would uphold the ordinances under the formal and substantive tests. Gaerlan, J., was on leave but left a vote. Rosario, J., joined the concurring and dissenting opinion of Justice Dimaampao. Lopez, J., was on leave but left a vote. Dimaampao, J., filed a concurring and dissenting opinion. Kho, Jr., J., joined the concurring and dissenting opinion of Justice Dimaampao. Senior Associate Justice Leonen concurred in dismissing the Petitions on mootness but discussed AI, privacy, and due process concerns and commended Justice Dimaampao's separate opinion.

• Justice Dimaampao — Concurred insofar as the ponencia effectively permits respondent LGUs to implement the NCAP through their respective ordinances, but strongly dissented from the majority's conclusion that the controversy had been rendered moot and academic by supervening events. He maintained that the legal framework remained the same, that respondent LGUs had not abolished their NCAP systems and intended to continue implementing them, and that thousands of motorists awaited resolution of the validity of fines. He would resolve the merits, found the NCAP ordinances valid except for the sentence in Valenzuela City Ordinance No. 918, series of 2021 stating that the budget for monthly honoraria shall come from the private sector partner, which he would declare unconstitutional for being contrary to public policy. He would dismiss the PNTOA et al. Petition for forum shopping and direct the RTC Manila to dismiss Case No. R-MNL-22-01122-SC, and would dismiss G.R. Nos. 261892 and 262192 for want of merit except for the declaration of unconstitutionality of the Valenzuela ordinance provision.