In 1979, LOI No. 869 was enacted. It banned vehicles classified as Heavy and Extra Heavy from being driven on weekends. Vehicles used for service, trucks, diplomatic cars, consular vehicles, and tourist cars are exempt. So, mainly, it affected private vehicle owners. The rationale of the LOI was to curb down fuel consumption; that there is a shortage of fuel supply; that fuel supply is unstable, hence, the need to regulate vehicles which are heavy or extra heavy on fuel consumption.
Mary Concepcion Bautista owns a vehicle which is classified as heavy / extra heavy. She now questions the constitutionality of LOI 869 on the ground that it was an invalid exercise of police power as it did not accord them due process and that it violates the equal protection clause. She argues that it prohibits her from enjoying the weekend with her family with the use of her car while affluent individuals who have multiple light vehicles can just avoid using their heavy vehicles – such only makes the LOI absurd and useless because it results in the rich using multiple small cars in the weekends.
ISSUE: Whether or not LOI 869 is valid.
HELD: Yes. The SC cannot inquire into the wisdom of LOI 869. Here, the President has laid down the basis of the LOI: limited fuel production in the global level, unstable fuel supply, increasing fuel prices, and the need to regulate fuel supply amidst these challenges. On its face, the LOI is reasonable. There was basis for its adoption.
In the State’s exercise of police power, it is established that use of private property may be regulated. If a law, on its face, is not arbitrary, oppressive, or unjust, it cannot be said that it violates due process.
Further, a law cannot be declared void simply because it failed to address all nuances. When the President came up with the LOI, he was presented with data and other needed information in relation to the problem sought to be addressed. Based on what was available, he thought the LOI was the best solution. The fact that it did not cover other matters which could very well have been regulated does not call for a declaration of its nullity. The President is not required by the Constitution to adhere to the policy of all or none. It is therefore clear that there was no violation of the equal protection clause.
