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Updated 9th March 2025
United States vs. Toribio
The case involved the defendant, Luis Toribio, who slaughtered a carabao without a permit, violating Act No. 1147. The Supreme Court ruled that the Act prohibits the slaughter of large cattle for human consumption anywhere in the Philippines without a permit, even in municipalities without a slaughterhouse. The Court upheld the constitutionality of the Act, stating that it was a valid exercise of police power to protect the general welfare and prevent the depletion of work animals.

Primary Holding

Act No. 1147 prohibits the slaughter of large cattle for human consumption anywhere in the Philippines without a permit, regardless of the presence of a municipal slaughterhouse. The law is a valid exercise of police power and not an infringement on private property rights.

Background

The case arose during a period when a contagious disease threatened the carabao population in the Philippines, impacting agriculture and the economy. Act No. 1147 was enacted to regulate the registration, branding, and slaughter of large cattle, aiming to protect the ownership and use of these animals.

History

  • The case was an appeal from a conviction in a lower court for violating Act No. 1147. The Supreme Court upheld the conviction and affirmed the sentence.

Facts

  • 1. The defendant, Luis Toribio, slaughtered a carabao for human consumption in the town of Carmen, Bohol, without a permit from the municipal treasurer. Carmen had no municipal slaughterhouse. The defendant argued that Act No. 1147 did not apply in the absence of a slaughterhouse.

Arguments of the Petitioners

  • 1. N/A

Arguments of the Respondents

  • 1. The defendant argued that Act No. 1147 did not prohibit or penalize the slaughter of large cattle without a permit in municipalities without a municipal slaughterhouse. He also argued that the Act was unconstitutional as it deprived him of his property without due process of law.

Issues

  • 1. Does Act No. 1147 prohibit and penalize the slaughter of large cattle without a permit in municipalities without a municipal slaughterhouse?
  • 2. Is Act No. 1147 a valid exercise of police power or an unconstitutional deprivation of property without due process of law?

Ruling

  • 1. Yes, Act No. 1147 prohibits and penalizes the slaughter of large cattle for human consumption anywhere in the Philippines without a permit, regardless of the presence of a municipal slaughterhouse.
  • 2. Act No. 1147 is a valid exercise of police power. It is a reasonable and necessary measure to protect the general welfare by preventing the depletion of work animals, especially during a period of significant loss due to disease.

Doctrines

  • 1. Police Power: The inherent power of the state to enact laws and regulations to promote the general welfare, safety, health, and morals of the public.
  • 2. Statutory Construction: When a statute is susceptible to multiple interpretations, the court should adopt the construction that best gives effect to the legislative intent and promotes the purpose of the statute.

Precedents Cited

  • 1. Commonwealth vs. Tewksbury (11 Met., 55): Used to support the argument that the law is a just and legitimate exercise of the power of the legislature to regulate and restrain the use of property for the public good.
  • 2. Commonwealth vs. Alger (7 Cush., 53, 84): Cited to distinguish between the exercise of eminent domain and the exercise of police power.
  • 3. Lawton vs. Steele (152 U. S., 133, 136): Cited to illustrate the wide range of areas where police power can be exercised.
  • 4. Thorpe vs. Rutland & Burlington R. R. Co. (27 Vt., 140): Cited to emphasize the state's right to impose restraints and burdens on persons and property to ensure the general welfare.

Statutory and Constitutional Provisions

  • 1. Section 5 of the Philippine Bill (Act of Congress, July 1, 1902): Cited to argue the unconstitutionality of the Act, but the Court ruled that the Act was a valid exercise of police power and not a deprivation of property without due process of law.