09/07/2026
The (SC) ๐๐ฏ ๐๐ข๐ฏ๐ค has dismissed the consolidated petitions challenging the ๐๐ฐ ๐๐ฐ๐ฏ๐ต๐ข๐ค๐ต ๐๐ฑ๐ฑ๐ณ๐ฆ๐ฉ๐ฆ๐ฏ๐ด๐ช๐ฐ๐ฏ ๐๐ฐ๐ญ๐ช๐ค๐บ (๐๐๐๐) in Metro Manila, ruling that the issues raised have become moot because of the adoption of a new and uniform traffic enforcement framework under the ๐๐ฆ๐ต๐ณ๐ฐ ๐๐ข๐ฏ๐ช๐ญ๐ข ๐๐ณ๐ข๐ง๐ง๐ช๐ค ๐๐ฐ๐ฅ๐ฆ ๐ฐ๐ง 2023 (๐๐๐๐ 2023). In addition to mootness, the petitions were also dismissed for lack of standing, violation of exhaustion of administrative remedies and hierarchy of courts, and forum-shopping.
In a Decision written by Associate Justice Rodil V. Zalameda, the SC dismissed the petitions filed by Kilusan sa Pagbabago ng Industriya ng Transportasyon and others. The petitions sought to declare unconstitutional ordinances of Muntinlupa City, Paraรฑaque City, Quezon City, Valenzuela City, and the City of Manila implementing ๐๐ฆ๐ต๐ณ๐ฐ ๐๐ข๐ฏ๐ช๐ญ๐ข ๐๐ฆ๐ท๐ฆ๐ญ๐ฐ๐ฑ๐ฎ๐ฆ๐ฏ๐ต ๐๐ถ๐ต๐ฉ๐ฐ๐ณ๐ช๐ต๐บ (๐๐๐๐) ๐๐ฆ๐ด๐ฐ๐ญ๐ถ๐ต๐ช๐ฐ๐ฏ ๐๐ฐ. 16-01, which established NCAP.
The NCAP seeks to ease traffic and reduce corruption through the use of digital cameras to detect traffic violations.
The petitioners argue that NCAP is inconsistent with ๐๐ฆ๐ฑ๐ถ๐ฃ๐ญ๐ช๐ค ๐๐ค๐ต ๐๐ฐ. (๐๐) 4136 ๐ฐ๐ณ ๐ต๐ฉ๐ฆ ๐๐ข๐ฏ๐ฅ ๐๐ณ๐ข๐ฏ๐ด๐ฑ๐ฐ๐ณ๐ต๐ข๐ต๐ช๐ฐ๐ฏ ๐ข๐ฏ๐ฅ ๐๐ณ๐ข๐ง๐ง๐ช๐ค ๐๐ฐ๐ฅ๐ฆ, which contemplates direct, face-to-face apprehension of violators and places responsibility on the actual driver rather than the registered vehicle owner. They also claim that NCAP violates due process because motorists may receive penalties without immediate notice or an opportunity to contest the violation when it occurs, which can result in fines accumulating before they are informed.
The SC ruled that the issues had been overtaken by later developments. The doctrine of constitutional avoidance requires courts to refrain from resolving constitutional questions where a case may be disposed of on non-constitutional grounds. Here, the traffic enforcement framework has since been changed by MMTC 2023, which is not being challenged in the present set of cases.
The SC noted that MMTC 2023 adopted by the Metro Manila Council established a uniform framework for traffic regulation and NCAP implementation across Metro Manila. It provides a uniform traffic adjudication system, procedures before traffic adjudication boards, periods for settling notices of violation, guidelines for tagging violations in the Land Transportation Officeโs (LTO) Land Transportation Management System, data privacy safeguards, uniform fines and penalties, recognized online payment platforms, and rules on the mandatory authorization process.
The MMDA later issued ๐๐ฆ๐ฎ๐ฐ๐ณ๐ข๐ฏ๐ฅ๐ถ๐ฎ ๐๐ช๐ณ๐ค๐ถ๐ญ๐ข๐ณ ๐๐ฐ. 10, ๐ด๐ฆ๐ณ๐ช๐ฆ๐ด ๐ฐ๐ง 2025, to implement MMTC 2023, which was adopted by Muntinlupa City, Paraรฑaque City, Quezon City, and Valenzuela City through new ordinances. The City of Manila also enacted an ordinance adopting the MMTC 2023, except the provision on the establishment of a Traffic Adjudication Board since its own Traffic Adjudication Board continues to perform its functions.
The SC said these developments effectively replaced the fragmented NCAP systems challenged in the petitions. Since neither MMTC 2023 nor the new ordinances were being challenged before the Court, any ruling on the validity of the old ordinances would have no practical or legal effect.
Although exceptions exist to allow the Court to resolve an otherwise moot case, such as when there is a grave violation of the Constitution, significant public interest, a need to formulate guiding principles, or when the case is likely to recur and evade review, none of these were present in this case.
The SC added that the dismissal does not bar future challenges if the revised NCAP system later gives rise to an actual controversy.
The SC also lifted the temporary restraining order it issued on August 30, 2022, against the City of Manila, Quezon City, Valenzuela City, Paraรฑaque City, Muntinlupa City, the LTO, and all parties acting for and on their behalf.
Read the full text of the press release at https://sc.judiciary.gov.ph/?p=168727
Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=168686
Read the Concurring and Dissenting Opinion of Senior Associate Justice Marvic M.V.F. Leonen at https://sc.judiciary.gov.ph/?p=168702
Read the Separate Opinion of Justice Amy C. Lazaro-Javier at https://sc.judiciary.gov.ph/?p=168712
Read the Concurring and Dissenting Opinion of Justice Japar B. Dimaampao at https://sc.judiciary.gov.ph/?p=168707
Copying of this content is subject to the SC PIOโs Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution
