On Thursday, July 9, the Supreme Court—in a decision written by Associate Justice Rodil V. Zalameda—dismissed petitions against the Metro Manila Development Authority’s (MMDA) no-contact apprehension program (NCAP). The petitions sought to challenge the NCAP’s validity, stating a contradiction in the Land Transportation and Traffic Code.
The petitions, filed by Kilusan sa Pagbabago ng Industriya ng Transportation and others, sought to declare unconstitutional ordinances regarding the NCAP in Manila, Muntinlupa, Parañaque, Valenzuela, and Quezon City. The petitions argued that the NCAP contradicts Republic Act No. 4136, which requires direct, face-to-face apprehension of violators and places the responsibility on the driver instead of the registered vehicle owner during apprehension.
Additionally, the petitioners also argued that the NCAP violates due process as penalties can be given without immediate notice. This leaves motorists unable to contest violations and can lead to compounding fines that they may be unaware of.
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However, the Supreme Court ruled that these issues have been superseded by later developments in the Metro Manila Traffic Code 2023 (MMTC 2023), noting that the revised code “now provides a uniform traffic adjudication system,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 Office’s Land Transportation Management System, data privacy safeguards, uniform fines and penalties, recognized online payment platforms, and rules on the mandatory authorization process.”
Because of the adoption of MMTC 2023, the issues raised were ruled moot. In this case, the new traffic enforcement framework is not being challenged by the present set of cases.
The MMDA has also issued Memorandum Circular No. 10, series of 2025, which implements MMTC 2023 in the aforementioned cities. And though the City of Manila has its own Traffic Adjudication Board, it has also enacted an ordinance that adopts MMTC 2023.
However, the Supreme Court also added that the dismissal does not bar future challenges if the revised NCAP system gives rise to a controversy, further clarifying that the dismissal of petitions does not constitute a ruling that the challenged NCAP issuances are valid.
“Our dismissal of the petitions is confined to the determination that petitioners failed to overcome threshold issues, and that the supervening adoption of a uniform regulatory framework has rendered the petitions moot,” the decision reads. “There is no explicit determination regarding the prior issuances, nor a resolution of grievances based on specific facts.”
