Primary Holding

Manila City Ordinance No. 7774, which prohibits short-time admission and wash-up rates in hotels and motels, is unconstitutional as it violates the due process clause of the Constitution.

Background

The City of Manila enacted an ordinance seeking to regulate public morals by prohibiting short-time rates in establishments often associated with illicit activities. Several businesses challenged the ordinance, arguing it infringed upon their rights and the rights of their customers. The case highlights the tension between government's power to regulate for public welfare and individual rights to liberty and privacy.

Facts

• 1. White Light Corporation, Titanium Corporation, and Sta. Mesa Tourist & Development Corporation, owners and operators of hotels and motels in Manila, challenged City Ordinance No. 7774, which prohibited "short-time admission, short-time admission rates, and wash-up rate schemes" in their establishments. The city government claimed the ordinance was a valid exercise of police power to protect public morals and welfare. The business owners argued that the ordinance was an invalid exercise of police power that infringed on their right to privacy, freedom of movement, and was an unreasonable interference in their businesses.

Arguments of the Petitioners

• 1. The ordinance is an invalid exercise of police power.
• 2. It violates the right to privacy and freedom of movement.
• 3. It is an unreasonable and oppressive interference with their business.
• 4. The ordinance makes a sweeping intrusion into the right to liberty of their clients.

Arguments of the Respondents

• 1. The ordinance is a valid exercise of police power under the Local Government Code and the Revised Manila Charter.
• 2. It aims to curb immoral activities and promote the general welfare.
• 3. It does not violate the right to privacy or freedom of movement, as it only penalizes the owners or operators of establishments.
• 4. The ordinance is justified by the well-being of its constituents in general.

Issues

• 1. Do the petitioners have the legal standing to challenge the ordinance?
• 2. Is Manila City Ordinance No. 7774 a valid exercise of police power?
• 3. Does the ordinance violate the due process clause of the Constitution?

Ruling

• 1. The Supreme Court ruled in favor of the petitioners, declaring the ordinance unconstitutional. The Court held that the ordinance violated the due process rights of both the businesses and their patrons. While the city's goal of minimizing illicit sexual activity, prostitution, and drug use was legitimate, the means employed (a blanket prohibition on short-time rates) were overly broad and unduly oppressive. The ordinance failed to distinguish between legitimate and illegitimate uses of the establishments and could easily be circumvented. The Court emphasized that less intrusive measures, such as stricter enforcement of existing laws against prostitution and drug use, would be more effective and less restrictive of individual rights.

Doctrines

• 1. Standing (Locus Standi): The ability of a party to demonstrate a sufficient connection to and harm from the law challenged to support their participation in the case. The court allowed third-party standing in this case, as the business owners could assert the rights of their customers.
• 2. Overbreadth Doctrine: A law is unconstitutional if it sweeps too broadly and prohibits constitutionally protected conduct along with conduct that may be legitimately regulated.
• 3. Police Power: The inherent power of the State to enact laws and regulations to promote public health, safety, morals, and general welfare.
• 4. Due Process: The constitutional guarantee that no person shall be deprived of life, liberty, or property without due process of law. This includes both procedural and substantive due process.
• 5. Substantive Due Process: Requires that the law itself, not merely the procedures used to implement it, be fair, reasonable, and justified by a legitimate government interest.
• 6. Rational Basis Test: A standard of judicial review that asks whether a law is rationally related to a legitimate government interest.
• 7. Strict Scrutiny: A more stringent standard of judicial review applied when a law infringes on fundamental rights or targets a suspect class. It requires a compelling government interest and narrowly tailored means.

Key Excerpts

• 1. "Liberty, as integrally incorporated as a fundamental right in the Constitution, is not a Ten Commandments-style enumeration of what may or what may not be done; but rather an atmosphere of freedom where the people do not feel labored under a Big Brother presence as they interact with each other, their society and nature, in a manner innately understood by them as inherent, without doing harm or injury to others."
• 2. "Individual rights may be adversely affected only to the extent that may fairly be required by the legitimate demands of public interest or public welfare. The State is a leviathan that must be restrained from needlessly intruding into the lives of its citizens."
• 3. "The behavior which the Ordinance seeks to curtail is in fact already prohibited and could in fact be diminished simply by applying existing laws."

Precedents Cited

• 1. City of Manila v. Laguio, Jr.: Affirmed the nullification of a city ordinance barring the operation of motels and inns within the Ermita-Malate area. Used to illustrate the protection of constitutional rights to liberty, due process, and equal protection.
• 2. Ermita-Malate Hotel and Motel Operations Association, Inc., v. Hon. City Mayor of Manila: Upheld the constitutionality of an ordinance requiring patrons to fill up a prescribed form with personal information before being admitted to a motel, hotel, or lodging house. Distinguished from the present case, as the present ordinance was deemed too restrictive.
• 3. Ynot v. Intermediate Appellate Court: Annulled a law banning inter-provincial transport of carabaos. Used as an analogy where a legitimate purpose was sought to be effected through an overly broad and restrictive measure.
• 4. Allen v. Wright: Discussed the constitutional standing requirements of injury, causation, and redressability.
• 5. Powers v. Ohio: Discussed the criteria for third-party standing.
• 6. Griswold v. Connecticut: Physicians had standing to challenge a reproductive health statute to plead the constitutional protections available to their patients.
• 7. Craig v. Boren: A licensed beverage vendor has standing to raise the equal protection claim of a male customer challenging a statutory scheme prohibiting the sale of beer to males under the age of 21 and to females under the age of 18.
• 8. U.S. v. Carolene Products: Established the "footnote 4" test acknowledging judicial deference to the legislature unless there is discrimination against a "discrete and insular" minority or infringement of a "fundamental right."
• 9. Roth v. Board of Regents: Sought to clarify the meaning of "liberty."

Statutory and Constitutional Provisions

• 1. Constitution, Article III, Section 1: Due process clause.
• 2. Local Government Code, Section 458 (4)(iv): Confers on cities the power to regulate establishments like hotels and motels.
• 3. Revised Manila Charter, Article III, Section 18(kk): Grants the city the power to enact ordinances for the promotion of morality, peace, good order, and general welfare.
• 4. Presidential Decree (P.D.) No. 259: Allegedly authorized MTDC to admit customers on a short-time basis and charge wash-up rates.