Republic Act No. 1180, which effectively nationalizes the retail trade business by prohibiting aliens (except US citizens and those already engaged in the business as of May 15, 1954, under specific conditions) from participating, constitutes a valid exercise of the State's police power and does not infringe upon the constitutional guarantees of due process and equal protection, nor does it violate treaty obligations or the constitutional requirement that the subject of a bill be expressed in its title.

he enactment of Republic Act No. 1180 stemmed from a deep-seated nationalistic concern, present since the 1935 Constitutional Convention and amplified over time, regarding the perceived economic dominance and control exerted by aliens, particularly in the vital retail trade sector, which was viewed as a threat to the Philippines' economic independence, national security, and the welfare of Filipino retailers and consumers.

N/A

• Republic Act No. 1180, titled "An Act to Regulate the Retail Business," prohibited persons not citizens of the Philippines, and associations/corporations not wholly owned by Filipinos, from engaging directly or indirectly in the retail trade.
• Exceptions were made for aliens already engaged in the retail business on May 15, 1954, who could continue until death or voluntary retirement (natural persons) or for ten years/expiration of term (juridical persons), and for citizens/entities of the United States.
• The Act also prohibited existing alien retailers from opening additional stores and required registration detailing their business.
• Petitioner Lao H. Ichong, an alien resident and retailer, filed this action for himself and others similarly affected, seeking a declaration that RA 1180 was unconstitutional and an injunction against its enforcement by the Secretary of Finance and Manila City Treasurer.
• Statistics presented indicated that while Filipinos outnumbered aliens in the retail sector, alien retailers (primarily Chinese) controlled a disproportionately large share of assets and gross sales, with significantly higher average capital investment and sales per establishment.
• The Court noted a general public perception, supported by historical context and legislative findings, that alien retailers dominated the distribution of essential goods and engaged in practices harmful to the national economy and consumers (e.g., price manipulation, hoarding, tax evasion, boycott, corruption).

• RA 1180 denies alien residents the equal protection of the laws by discriminating against them based solely on nationality.
• The Act deprives alien residents of their liberty (to choose an occupation) and property (their existing retail businesses and goodwill) without due process of law, as retail is a common and lawful occupation.
• The subject of the Act (nationalization and prohibition of aliens in retail) is not adequately expressed in its title ("An Act to Regulate the Retail Business"), violating the Constitution.
• RA 1180 violates international law principles and specific treaty obligations, particularly the Treaty of Amity between the Philippines and the Republic of China, and contradicts the spirit of the UN Charter and the Declaration of Human Rights.
• Provisions restricting hereditary succession of retail businesses by alien heirs and requiring 100% Filipino ownership for corporations violate constitutional principles regarding property rights and economic development.
• The alleged alien dominance and threat are exaggerated or unfounded, and the law is motivated by racial prejudice and undue nationalism rather than genuine public interest.

• RA 1180 represents a valid exercise of the State's inherent police power, aimed at protecting the national economic interest, survival, and security from the dangers of alien control over the vital retail sector.
• The classification between citizens and aliens is reasonable and constitutionally permissible, based on inherent differences in loyalty, objectives, potential threat in times of crisis, and historical conduct affecting public welfare.
• The Act's title, "An Act to Regulate the Retail Business," sufficiently complies with the constitutional requirement, as "regulation" is a broad concept that can include restriction and prohibition.
• No treaty or international obligation is violated; the Treaty of Amity with China only guarantees parity with other aliens (who are also prohibited), not with nationals, and treaties are subordinate to police power and subsequent domestic legislation.
• The law is prospective and includes provisions reasonably protecting the rights of aliens already engaged in the business (grandfather clause), thus satisfying due process requirements. Hereditary succession is subject to statutory regulation.

• Whether Republic Act No. 1180 violates the equal protection clause of the Constitution.
• Whether Republic Act No. 1180 violates the due process clause of the Constitution.
• Whether the subject of Republic Act No. 1180 is sufficiently expressed in its title as required by the Constitution.
• Whether Republic Act No. 1180 violates international law or treaty obligations of the Philippines.

• The Supreme Court denied the petition and upheld the constitutionality of Republic Act No. 1180.
• The Act does not violate the equal protection clause because the classification between citizens and aliens in the context of retail trade is based on substantial distinctions (loyalty, contribution to national wealth, potential security risk, past conduct) relevant to the legislative purpose of securing the national economy, making the differential treatment reasonable.
• The Act does not violate the due process clause as it was enacted under the State's police power to address a perceived real threat to public welfare and national security (alien dominance in retail). The means chosen (gradual nationalization with exceptions for existing alien retailers) bear a reasonable relation to the legitimate legislative objective and are not unduly oppressive or arbitrary.
• The title "An Act to Regulate the Retail Business" satisfies the constitutional requirement; "regulate" is a broad term that encompasses the means used in the Act, including prohibition and nationalization, and the title sufficiently informed legislators and the public of the law's general subject matter.
• The Act does not violate international law or treaty obligations; the UN Charter and Declaration of Human Rights do not create binding legal obligations in this regard, the Treaty of Amity with China is not infringed as all aliens (except US citizens) are treated similarly, and treaties are generally subject to the State's police power and subsequent legislation.

• Police Power: Defined as the State's inherent power to enact legislation promoting public welfare, safety, morals, and economic security. RA 1180 was upheld as a legitimate exercise of this power to address perceived economic dangers from alien control of retail trade, deemed essential for national survival and independence.
• Due Process of Law: Interpreted as requiring that laws shall not be unreasonable, arbitrary, or capricious, and that the means selected shall have a real and substantial relation to the object sought. Applied to RA 1180, the Court found the law's objective (economic protection) legitimate and the means (nationalization with exceptions) reasonably related and not unduly oppressive given the circumstances.
• Equal Protection of the Laws: Construed as prohibiting undue favor and hostile discrimination but allowing for reasonable classification. Applied by finding that the distinction between aliens and citizens in retail trade was based on real differences relevant to the law's purpose (national economic security), thus justifying the classification.
• Legislative Discretion: The principle that the legislature is primarily the judge of the necessity, adequacy, and wisdom of laws enacted under police power. The Court deferred to the legislature's judgment regarding the existence of the economic threat and the appropriateness of RA 1180 as a remedy, refusing to inquire into the law's wisdom.
• Presumption of Constitutionality: The doctrine that laws are presumed valid unless proven otherwise beyond reasonable doubt. Applied in favor of RA 1180, placing the burden on the petitioner to demonstrate its constitutional infirmity.
• Citizenship as Basis for Classification: Affirmed that citizenship can be a valid basis for legislative classification in the exercise of police power, particularly concerning activities vital to national interest and economy, citing precedents like Smith Bell & Co. vs. Natividad.
• Sufficiency of Title (Constitutional Requirement): Interpreted liberally, holding that a general title encompassing the law's main subject is adequate, and need not be a detailed index. The term "regulate" in RA 1180's title was deemed broad enough to include prohibition and nationalization.
• Treaty Subordination to Police Power and Statute: Stated that the State's police power cannot be contracted away by treaty and that a treaty may be superseded or qualified by a subsequent valid statute enacted by the legislature.

• "Admittedly springing from a deep, militant, and positive nationalistic impulse, the law purports to protect citizen and country from the alien retailer."
• "It has been said that police power is so far-reaching in scope, that it has become almost impossible to limit its sweep... it is said to be co-extensive with self-protection and survival..."
• "The police power legislation must be firmly grounded on public interest and welfare, and a reasonable relation must exist between purposes and means."
• "The equal protection of the law clause is against undue favor and individual or class privilege, as well as hostile discrimination or the oppression of inequality."
• "...the legislature... is by force of circumstances primarily the judge of necessity, adequacy or reasonableness and wisdom, of any law promulgated in the exercise of the police power..."
• "We are fully satisfied... that the disputed law is not the product of racial hostility, prejudice or discrimination, but the expression of the legitimate desire and determination of the people... to free the nation from the economic situation that has unfortunately been saddled upon it..."
• "...the guaranty of due process... demands only that the law shall not be unreasonable, arbitrary or capricious, and that the means selected shall, have a real and substantial relation to the subject sought to be attained."
• "The Legislature is primarily the judge of the necessity of an enactment... and every presumption is in favor of its validity... it may not annul the legislation if not palpably in excess of the legislative power."

• Yick Wo vs. Hopkins: Referenced to establish that constitutional guarantees apply to aliens, but distinguished because RA 1180 was deemed based on economic policy, not racial hostility or arbitrary enforcement.
• Lindsley vs. Natural Carbonic Gas Co.: Cited and followed for the standards in evaluating equal protection challenges, emphasizing legislative discretion and the presumption of a factual basis for classification.
• Smith Bell & Co. vs. Natividad: Relied upon as key Philippine precedent upholding citizenship as a valid basis for classification under police power in economic regulation (coastwise trade).
• Ohio ex rel. Clarke vs. Deckebach: Cited as US Supreme Court precedent allowing classification based on alienage where related to a legitimate legislative object (regulating pool halls), emphasizing deference to legislative assessment of local conditions.
• Nebbia vs New York: Cited and followed for the principle that due process requires only reasonableness and a rational relation between means and ends in economic regulation under police power.
• Lawton vs. Steele: Referenced for the test requiring state interference under police power to serve public interests via reasonably necessary and non-oppressive means.
• Yu Cong Eng vs. Trinidad: Distinguished, as the law invalidated therein (bookkeeping law) was found to lack public benefit and harm the affected aliens' ability to conduct business, unlike RA 1180 which was seen as serving a vital public interest.
• U. S. vs. Thompson; Palston vs. Pennsylvania: Cited to support the principle that treaties are subject to the State's police power and can be modified by subsequent legislation.
• Multiple state court decisions (e.g., Commonwealth vs. Hana, Bloomfield vs. State, Anton vs. Van Winkle): Used illustratively to show instances where alienage was upheld as a basis for classification in regulating various trades.
• Multiple state/federal court decisions (e.g., Templar vs. Michigan State Board, Takahashi vs. Fish and Game Comm.): Distinguished as cases where alienage classifications were struck down due to arbitrariness, racial motivation, or conflict with federal power, unlike RA 1180.

• Republic Act No. 1180 (Subject of the case)
• Philippine Constitution (1935), Article III, Section 1(1) (Due Process and Equal Protection Clause)
• Philippine Constitution (1935), Article VI, Section 21(1) (Subject and Title of Bills Clause)
• Philippine Constitution (1935), Article XIV, Section 8 (Nationalization of Public Utilities Clause - cited for context)
• Philippine Constitution (1935), Preamble (Cited for nationalistic objectives like conservation of patrimony)
• Treaty of Amity between the Republic of the Philippines and the Republic of China (April 18, 1947) (Claimed to be violated by petitioner)
• Charter of the United Nations (Argued as basis for violation, but deemed non-binding legally by the Court)
• Universal Declaration of Human Rights (Argued as basis for violation, but deemed a non-binding recommendation by the Court)