The Supreme Court (SC) on Thursday dismissed the petitions opposing the No Contact Apprehension Program (NCAP) implemented by the Metropolitan Manila Development Authority (MMDA), declaring the issues raised now “moot” with the adoption of a new traffic enforcement framework.
“The petitioners argue that NCAP is inconsistent with Republic Act No. 4136 or the Land Transportation and Traffic Code, which contemplates direct, face-to-face apprehension of violators and places responsibility on the actual driver rather than the registered vehicle owner,” the SC wrote of the petitioner’s position.
“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 court added.
However, the SC said the Metro Manila Traffic Code of 2023 (MMTC 2023), adopted with the issuance of Memorandum Circular No. 10, s. 2025, has replaced the systems challenged in the petitions.
The MMTC 2023 sets one standard system for handling traffic violations, the procedures before traffic adjudication boards, deadlines for settling notices of violation, rules for recording violations in the Land Transportation Office (LTO) management system, data privacy protections, uniform fines and penalties, approved online payment platforms, and the required authorization process, the SC said.
This traffic code is currently in implementation in Muntinlupa City, Parañaque City, Quezon City, Valenzuela City, and the City of Manila.
“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,” the High Court said.
In addition, the Court lifted the temporary restraining order (TRO) issued against the cities of Manila, Quezon, Valenzuela, Parañaque, Muntinlupa, the LTO and others acting on the agency’s behalf.
Three justices said the validity of the NCAP ordinances should still be addressed, even if some issues had already been overtaken by the MMTC 2023.
Senior Associate Justice Marvic M.V.F Leonen said the NCAP’s mode of apprehension still calls for a resolution but maintained that the ordinances themselves were valid and did not violate due process, privacy, or other laws.
Likewise, Associate Justice Amy C. Lazaro-Javier said the ordinances’ validity must be settled to prevent the same issues from resurfacing. While Associate Justice Japar B. Dimaampao agreed that the ordinances should not be invalidated, he argued that the issues surrounding NCAP were not moot, citing the unchanged legal framework, the continued implementation of the policy, and ongoing concerns over fines.
