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New Case Digest For Consti
New Case Digest For Consti
L-24693
ERMITA-MALATE HOTEL AND MOTEL OPERATORS ASSOCIATION, INC., HOTEL DEL
MAR, INC. and GO CHIU, petitioners-appellees, vs. THE HONORABLE CITY MAYOR OF
MANILA, respondent-appellant, VICTOR ALABANZA, intervenor-appellee
Facts:
The petitioners, Ermita-Malate Hotel and Motel Operators Association, along with Hotel del Mar
Inc. and Go Chiu, filed a petition against Ordinance No. 4760 and the Mayor of the City of
Manila, who was responsible for enforcing city ordinances. The petitioners argued that the
ordinance, enacted in 1963, was inappropriately regulating motels, as there was no legal basis for
such regulation in the City of Manila's charter or other laws. The ordinance also allowed
authorities to inspect the premises of hotels, motels, and lodging houses. The lower court issued
a preliminary injunction on July 6, 1963, preventing the Mayor from enforcing Ordinance No.
4760 starting from July 8, 1963.
Issues:
Whether or Not Ordinance No. 4760 of the City of Manila is unconstitutional
Ruling:
No. The lower court's sweeping condemnation of the challenged ordinance was inconsistent with
constitutional principles. Decisions should align with established standards of constitutional
adjudication, both in procedure and substance. There is a presumption of the validity of a law,
and the judiciary should not readily overturn legislative action unless it clearly infringes on
personal or property rights under the guise of police regulation. The challenged ordinance aimed
to reduce practices harmful to public morals, particularly fornication and prostitution, and also
increased licensing fees to discourage illegal operations while boosting the city's revenue.
Legal concept:
The exercise of police power, which is the power to prescribe regulations to promote the health,
morals, peace, good order, safety, and general welfare of the people, is subject to judicial inquiry
to ensure it is not capricious, whimsical, unjust, or unreasonable and does not violate any
constitutional guarantees. Municipal ordinances are presumed to be valid unless there is a clear
invasion of personal property rights under the guise of police regulation.
G.R. No. 14078
RUBI, ET. AL. (Manguianes), plaintiffs,vs.THE PROVINCIAL BOARD OF MINDORO, defendant
Facts:
On February 1, 1917, the provincial board of Mindoro passed Resolution No. 25, which was
approved by the Secretary of the Interior on February 21, 1917. Subsequently, on December 4,
1917, the provincial governor of Mindoro issued Executive Order No. 2, stating that Rubi and
those in his rancheria hadn't relocated to the Tigbao reservation, making them subject to
punishment under Section 2759 of Act No. 2711. The provincial governor directed the
Manguianes to settle in Tigbao, a location approved by the provincial board and chosen by the
governor, in accordance with Section 2145 of the Administrative Code of 1917. This action's
validity, particularly the challenge to Section 2145 of the Administrative Code, is the central
issue before the court.
Issues:
Whether or Not the provision in Section 2145 of the Administrative Code of 1917, which authorizes
provincial governors to direct non-Christian inhabitants to live on designated public lands, is
constitutional.
Ruling:
In a Supreme Court decision with a five to four vote, the constitutionality of a section of the
Administrative Code was upheld. It was clarified that the term "non-Christian" should not be
interpreted in a literal or religious sense, but rather in terms of the level of civilization. "Non-
Christian" was understood to refer to geographical location and, more specifically, to natives of
the Philippines with a lower level of civilization, not their religious beliefs. The Court
emphasized that the Philippine Organic Law did not impede the government of the Philippine
Islands from exercising its sovereign police power through legislation to promote the general
welfare and public interest. The law in question was found to be a legitimate exercise of police
power, particularly in relation to the prompt registration of land titles, which served the public
interest by promoting peace, order among landowners, economic development, and overall
prosperity. The Court also determined that the provincial board of Mindoro's resolution was not
discriminatory or class legislation, as it aimed to benefit both the Manguianes and the Philippines
as a whole. Due process of law and equal protection of the laws were deemed to be observed in
the enforcement of this law, as it applied uniformly to all within a specific class.
Legal concept:
Police power, in the promotion of the general welfare and the public interest, when to advance
the public welfare, the law was found to be a legitimate exertion of the police power. The court
held that Section 2145 of the Administrative Code of 1917 does not violate the principles of due process
of law, equal protection of the laws, or religious discrimination. The court reasoned that the authority
conferred upon executive officials by the provision does not unduly interfere with the liberty of the
citizens, considering the low level of civilization of the Manguianes.
G.R. No. L-7995
LAO H. ICHONG, in his own behalf and in behalf of other alien residents, corporations and partnerships
adversely affected by Republic Act No. 1180, petitioner, vs. JAIME HERNANDEZ, Secretary of Finance,
and MARCELINO SARMIENTO, City Treasuer of Manila, respondent
Facts:
The constitutionality of Republic Act No. 1180, which nationalizes the retail trade business in the
Philippines. The petitioner, Lao H. Ichong, filed a petition on behalf of himself and other alien residents,
corporations, and partnerships adversely affected by the law. The respondents in the case are Jaime
Hernandez, the Secretary of Finance, and Marcelino Sarmiento, the City Treasurer of Manila. The
petitioner argues that the law violates the equal protection of the laws and deprives alien residents of their
liberty and property without due process. They also claim that the law violates international and treaty
obligations and certain provisions of the Constitution
Issues:
Whether or Not Republic Act No. 1180 is constitutional, particularly with regards to the equal protection
of the laws, due process, and international obligations
Ruling:
The Supreme Court upheld the constitutionality of Republic Act No. 1180. The Court determined that the
law was enacted in a legitimate exercise of the government's police power, as permitted by the
Constitution for the purpose of safeguarding national economic survival. Additionally, the Court
concluded that the law didn't contravene international agreements or treaty obligations. Moreover, it was
held that the law didn't discriminate among individuals within a specific category (alien retailers), thereby
not violating equal protection under the law. The Court also found that the law's stipulations regarding
hereditary succession and capitalization requirements for corporations were in accordance with the
relevant provisions of the Constitution.
Legal concept:
The Court explained that police power is far-reaching in scope and is co-extensive with self-protection
and survival. The power and the guarantees of due process and equal protection of the laws are supposed
to coexist, with the balancing of these interests being the essence of a democratic society. The Court also
emphasized that the equal protection of the law clause does not prohibit legislation that applies only to a
specified class, as long as it applies alike to all persons within that class and there is a reasonable basis for
the distinction. The Court found that the classification in the law of retail traders into nationals and aliens
is actual, real, and reasonable, and that the law is necessary to bring about the desired legislative objective
of nationalizing the retail trade business.