Case Digest (G.R. No. 118127) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In City of Manila, et al. v. Perfecto A.S. Laguio, Jr., G.R. No. 118127, decided April 12, 2005, private respondent Malate Tourist Development Corporation (MTDC), operator of Victoria Court—a motel in Manila’s Ermita-Malate district—filed on June 28, 1993 a petition for declaratory relief, injunctive relief and preliminary injunction before the Regional Trial Court (RTC), Manila, Branch 18, challenging Ordinance No. 7783 of March 9, 1993 (approved March 30, 1993). The ordinance prohibited within fixed boundaries the establishment or operation of “certain forms of amusement, entertainment, services and facilities” including motels and inns, and prescribed penalties including forced closure. MTDC contended the City Council only had power to regulate—and not prohibit—motels under Sections 458(a)(4)(iv) and 458(a)(4)(vii) of the Local Government Code (LGC) and that the ordinance conflicted with Presidential Decree No. 499, violated due process, equal protection and constituted an un Case Digest (G.R. No. 118127) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Subject Matter
- Petitioners: City of Manila, its Mayor (Alfredo S. Lim), Vice-Mayor (Joselito L. Atienza) and all city councilors—enactors of Ordinance No. 7783.
- Private Respondent: Malate Tourist Development Corporation (MTDC), owner and operator of Victoria Court motel in Ermita-Malate, licensed as a motel and accredited as a hotel by the Department of Tourism.
- Ordinance No. 7783 (“Ordinance”)
- Enacted by City Council on 9 March 1993, approved by the Mayor on 30 March 1993.
- Prohibited establishments in the Ermita-Malate area (Kalaw St., Taft Ave., Vito Cruz St., Roxas Blvd.): sauna parlors, massage parlors, karaoke bars, beerhouses, night clubs, day clubs, super clubs, discotheques, cabarets, dance halls, motels, inns (Sec. 1).
- Barred issuance of permits/licenses for such businesses (Sec. 2).
- Gave owners three months to wind up, transfer outside area, or convert to allowable businesses (e.g., galleries, restaurants) (Sec. 3).
- Imposed penalty of one-year imprisonment and/or ₱5,000 fine; permanent padlocking on repeat violation (Sec. 4); effective upon approval (Sec. 5).
- Proceedings Below
- 28 June 1993: MTDC filed Petition for Declaratory Relief with Prayer for Writ of Preliminary Injunction/TRO in RTC Manila, challenging Ordinance as invalid, unconstitutional, ultra vires, repugnant to PD 499, ex post facto, confiscatory, and violative of due process and equal protection.
- 28 June 1993 & 16 July 1993: RTC issued TRO and granted preliminary injunction.
- 25 November 1994: RTC rendered decision declaring Ordinance null and void and made injunction permanent.
- Petitioners appealed to the Supreme Court under Rule 42 (then Rule 45), raising pure questions of law.
Issues:
- Whether the City Council had power under the Local Government Code to prohibit—as opposed to regulate—motels, inns and similar establishments.
- Whether Ordinance No. 7783 is repugnant to Presidential Decree No. 499, which classified Ermita-Malate as a commercial zone.
- Whether the Ordinance constitutes a valid exercise of police power under the Constitution and applicable statutes (due process and reasonableness).
- Whether the Ordinance is an ex post facto law penalizing existing business.
- Whether the Ordinance is confiscatory and constitutes an unlawful taking without just compensation.
- Whether the Ordinance violates equal protection by arbitrary classification (motels/inns vs. other lodging establishments, and gender-based provisions).
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)