This document proposes an RT-MMF algorithm to control congestion in vehicular ad hoc networks (VANETs) and safely deliver safety messages. It compares the proposed technique to an existing adaptive and mobility-based algorithm (AMBA). The RT-MMF algorithm uses an active/deactive concept to save energy by only activating nodes responsible for message transmission. It also applies a relaxation theory and max-min fairness approach for congestion control and selects the transmission path based on minimum distance calculations between neighboring nodes. Simulation results show the proposed technique improves energy efficiency, packet delivery ratio, throughput and reduces delay compared to AMBA.