The Supreme Court dismissed three consolidated petitions that sought to nullify city ordinances implementing the No Contact Apprehension Policy (NCAP) in certain cities in Metro Manila, ruling that the petitions were marred by fundamental procedural defects that prevented the Court from exercising its power of judicial review.
The Court held that the petitions were dismissed for being moot and for failure to satisfy the requisites of judicial review. It stressed that procedural rules are not suspended by mere prominence of the controversy presented, and that it cannot act when its jurisdiction has not been properly invoked.
The Case
Before the Court were three consolidated petitions for certiorari and prohibition with prayers for injunctive relief, all seeking nullification of city ordinances implementing the NCAP in certain cities in Metro Manila (NCAP City Ordinances) for being in contravention of national statutes and violative of constitutionally protected rights.
In G.R. No. 261892, the petition was filed by Kilusan sa Pagbabago ng Industriya ng Transportasyon, Inc. (KAPIT), Pangkalahatang Sanggunian Manila & Suburbs Drivers Association Nationwide, Inc. (PASANG MASDA), Alliance of Transport Operators and Drivers Association of the Philippines (ALTODAP), and Alliance of Concerned Transport Organization (ACTO) against the City of Manila, Quezon City, Valenzuela City, Parañaque City, Muntinlupa City, and the Land Transportation Office (LTO).
In G.R. No. 262192, the petition was filed by Atty. Juman B. Paa against the Sangguniang Panglungsod ng Maynila and Hon. Dr. Maria Sheilah Lacuna-Pangan, in her capacity as then incumbent mayor of the City of Manila.
In G.R. No. 263752, the petition was filed by Philippine National Taxi Operators Association, Inc., Manuel C. Cruz, and Jacqueline V. Serrano against the respondent LGUs and the Metropolitan Manila Development Authority (MMDA).
According to the decision, 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 (MMC) issued resolutions, including MMDA Resolution No. 16-01, to adopt and implement a "No Physical Contact Policy" for apprehension of traffic violators through the use of digital cameras, aimed at reducing traffic congestion and curbing opportunities for corruption. The MMC later authorized the use of closed-circuit television (CCTV) cameras, digital imaging, and similar technologies, 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.
The Issue
The Court framed the matter around whether the petitions properly invoked its power of judicial review, or whether they were barred by procedural defects such as mootness, lack of standing, violation of the doctrines of exhaustion of administrative remedies and hierarchy of courts, and forum-shopping.
The Ruling
The Court dismissed the petitions. Its disposition reads: "ACCORDINGLY, the Petitions for Certiorari and Prohibition in G.R. No. 261892 filed by Kilusan sa Pagbabago ng Industriya ng Transportasyon, Inc., Pangkalahatang Sanggunian Manila & Suburbs Drivers Association Nationwide, Inc., Alliance of Transport Operators and Drivers Association. of the Philippines, and Alliance of Concerned Transport Organization; G.R. No. 262192 filed by Atty. Juman B. Paa; and G.R. No. 263752 filed by Philippine National Taxi Operators Association, Inc., Manuel C. Cruz, and Jacqueline V. Serrano are DISMISSED for being moot and for failure to satisfy the requisites of judicial review."
The Court also lifted the Temporary Restraining Order issued on August 30, 2022 against the City of Manila, Quezon City, Valenzuela City, Parañaque City, Muntinlupa City, the Land Transportation Office, and all parties acting for and on their behalf.
The Court emphasized that these reminders should not be construed as a ruling on the constitutionality of the assailed issuances.
By the Numbers
- Three consolidated petitions: G.R. Nos. 261892, 262192, and 263752.
- Decision promulgated: June 3, 2026.
- Temporary Restraining Order issued: August 30, 2022.
- MMDA Resolution No. 16-01 (MMDA NCAP), dated February 16, 2016.
- MMDA Resolution No. 02-49, dated November 7, 2002.
- MMDA Resolution No. 09-02, dated January 21, 2009, prescribing the policy on a trial basis for a period of Ninety Days.
The Court's Reasoning
The Court explained that while the controversy appeared ground-breaking, far-reaching, and even intimidating at first glance, courts decide cases based on jurisdiction, not on appearances. It stated that it cannot disregard the requisite procedural stages and "skip to the good part."
The Court declared that a petitioner must allege and establish a direct, personal, and substantial injury that is actual or imminent, and not merely speculative or generalized. It added that mere allegations of possible system errors and speculative effects of imposition of penalties are insufficient.
On the hierarchy of courts, the Court said direct recourse to it is permitted only upon a showing of special and compelling reasons, and that where the regulatory framework provides mechanisms to contest enforcement actions, such remedies must be availed of and completed prior to judicial action. A mere invocation of constitutional issues does not dispense with this requirement.
The Court also noted that a petition must present an actual and justiciable case, and that it will not render advisory opinions or pass upon the validity of policies in the abstract. On mootness, it said that where a challenged issuance has been modified, discontinued, or abandoned, a petitioner must demonstrate that a live controversy remains, or that the case falls within recognized exceptions to mootness.
The Court further stated that, in a democracy, the end does not justify the means, and that no objective, no matter how laudable, justifies transgression of fundamental human rights. It said threshold grounds determined the disposal of the petitions, and these jurisdictional defects foreclosed further inquiry on the substantive issues.
Source: Supreme Court En Banc Decision in G.R. Nos. 261892, 262192, and 263752, promulgated June 3, 2026, penned by Justice Zalameda.
This report summarizes a public Supreme Court decision and is not legal advice.