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Bautista vs. Junio.

G.R. No. L-50908. Jan. 31, 1984

FACTS: Petitioner spouses Bautista assailed the constitutionality of Letter of Instruction No. 869
promulgated on 1979 which classifies vehicles as Heavy and Extra Heavy. Further, the LOI banned
these vehicles on week-ends and holidays from 5AM Saturday to 5AM Monday. These measures were
promulgated with the end goal of curbing the petroleum consumption as bigger cars consume more
fuel.

PETITIONER’S CONTETION: The petitioner claimed that:


1. It is discriminatory as it made an assumption that Heavy and Extra Heavy cars are heavy on
petroleum consumption when in fact there are smaller cars which are also big on fuel
consumption.
2. It restricts their freedom to enjoy their car while others who have smaller cars may enjoy theirs.
3. There is no rational justification for the ban being imposed on vehicles classified as heavy (H) and
extra-heavy (EH).

ISSUE: Whether the assailed LOI is unconstitutional.

HELD: NO. The SC held that Bautista the contention of the petitioners was unmeritorious.

The Supreme Court ruled that the measure was a valid exercise of police power. And that this
measure is an appropriate response to the problem that processes urgently for solution., wherein its
reasonableness is immediately apparent. Thus, the substantive due process is not ignored, much less
infringed. Settled in our jurisprudence that the exercise of police power may cut into the rights to
liberty and property of an individual for the promotion of the general welfare; and that those
adversely affected may invoke the equal protection clause only if they can show a factual foundation
for its invalidity.

This petition was dismissed because of the presumption of constitutionality. The principle enunciated
in O’Gorman v. Hartford has been recognized which provides that the in case of statutes with a subject
clearly within the scope of police power, the Court is tasked to declare it void on the ground that the
specific method or regulation Is unreasonable and hence deprives the plaintiff of due process of law.
And since this is a question of fact, there is a need for factual foundation overthrowing the assumption
of validity of statute.

Moreover, in cases where there is an interplay between such fundamental right and police power, the
latter is being accorded with mcuch leeway. To rule otherwise would unduly restrict and narrow the
scope of police power which ha been properly characterized as the most essential, insistent, and the
least limitable of powers, extending to all great pubic needs.

Furthermore, the Court ruled that there was NO VIOLATION of right to EQUAL PROTECTION of the
petitioner. The Corut ratiocinated that violation to the equal protection clause cannot be invoked if
the petitioners can show that the governmental act assailed are inspired far from the attainment of
the common good and was prompted by the spirit of hostility or at the very least, discrimination.

In the case at bar, the petitioner was not able to demonstrate such and the court ruled that it is
sufficient for the laws to operate equally and uniformly on all persons under similar circumstances
OR that all persons must be treat in the same manner, the conditions not being different, both in the
privileges granted by the state and the liabilities it imposed.
NOTE:
● Administrative interpretation of law is merely advisory, for it is the courts that finally
determine what the law means.

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