Calalang vs Williams, Constitutional Law Digest

September 9, 2008

G.R. No. 47800.  December 2, 1940

MAXIMO CALALANG, petitioner, vs. A. D. WILLIAMS, ET AL., respondents.Maximo Calalang in his own behalf.

The case of Calalang vs Williams is known for the elegant exposition of the definition of social justice.  In this case, Justice Laurel defined social justice as “neither communism, nor despotism, nor atomism, nor anarchy” but humanization of laws and equalization of social and economic forces by the State so that justice in its rational and objectively secular conception may at least be approximated.

As I browse through the entire case, I found out that there is more to this case than the definition of social justice.  In fact, another important issue raised here is whether there was a valid delegation of power by the National Assembly to the Director of Public Works.  Let us begin with the facts of the case.

Facts:

In pursuance of Commonwealth Act 548 which mandates the the Director of Public Works, with the approval of the Secretary of Public Works and Communications, shall promulgate the necessary rules and regulations to regulate and control the use of and traffic on such roads and streets  to promote safe transit upon, and avoid obstructions on, roads and streets designated as national roads, the Director of Public Works adopted the resolution of the National Traffic Commission, prohibiting the passing of animal drawn vehicles in certain streets in Manila.  

Petitioner questioned this as it constitutes an undue delegation of legislative power.

Issues: 

Whether or not there is a undue delegation of legislative power? (more…)